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The HC quashed the reopening of assessment under section 147, finding that the tax authorities recorded reasons without examining the assessee's records or addressing objections. Regarding wage revision provisions under section 115JB, the Court noted that CIT(A) had already deleted this addition with the AO's concurrence before reopening was initiated. On interest on non-performing investments, the Court held that banking companies are governed by Banking Regulation Act, not Schedule III of Companies Act, 2013. Concerning deductions under section 36(1)(viia), the Court found this issue was previously examined during original assessment proceedings. The Court concluded the reopening constituted an impermissible review based on change of opinion, and the order disposing of objections lacked proper reasoning.
The HC quashed the reopening of assessment under section 147, finding that the tax authorities recorded reasons without examining the assessee's records or addressing objections. Regarding wage revision provisions under section 115JB, the Court noted that CIT(A) had already deleted this addition with the AO's concurrence before reopening was initiated. On interest on non-performing investments, the Court held that banking companies are governed by Banking Regulation Act, not Schedule III of Companies Act, 2013. Concerning deductions under section 36(1)(viia), the Court found this issue was previously examined during original assessment proceedings. The Court concluded the reopening constituted an impermissible review based on change of opinion, and the order disposing of objections lacked proper reasoning.
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