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The assessee claimed excess deduction u/s 36(1)(viia) for provision for bad and doubtful debts, leading to escapement of income. The Assessing Officer rightly formed the belief of income escapement based on assessment records obtained from the Income Tax Officer, revealing the excess deduction claim. It was not a case of change of opinion, as the statutory provisions u/s 36(1)(viia) limit the deduction to 7.5% of total income, leaving no room for differing opinions. The tangible material justified reopening the assessment, and the assessee's reliance on the Delta Airlines case was misplaced. The appeal was dismissed, as it was a clear case of income escapement due to excess deduction claimed, contrary to statutory provisions.
The assessee claimed excess deduction u/s 36(1)(viia) for provision for bad and doubtful debts, leading to escapement of income. The Assessing Officer rightly formed the belief of income escapement based on assessment records obtained from the Income Tax Officer, revealing the excess deduction claim. It was not a case of change of opinion, as the statutory provisions u/s 36(1)(viia) limit the deduction to 7.5% of total income, leaving no room for differing opinions. The tangible material justified reopening the assessment, and the assessee's reliance on the Delta Airlines case was misplaced. The appeal was dismissed, as it was a clear case of income escapement due to excess deduction claimed, contrary to statutory provisions.
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