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ITAT held the reopening of assessment under s.147/s.148 invalid, finding the AO's action amounted to impermissible change of opinion as no fresh material surfaced post-assessment and the original return and notes were fully considered; the sanction by the CIT(A) was mechanical ("yes, I am satisfied") and therefore vitiated, so the reassessment proceedings and notice under s.148 are quashed. Separately, the Tribunal upheld the assessee's accounting treatment of goodwill under the purchase method for computation of book profit under s.115JB, directing the AO to delete adjustments and allow amortisation/depreciation on goodwill as reflected in the approved merger scheme and audited financials.
ITAT held the reopening of assessment under s.147/s.148 invalid, finding the AO's action amounted to impermissible change of opinion as no fresh material surfaced post-assessment and the original return and notes were fully considered; the sanction by the CIT(A) was mechanical ("yes, I am satisfied") and therefore vitiated, so the reassessment proceedings and notice under s.148 are quashed. Separately, the Tribunal upheld the assessee's accounting treatment of goodwill under the purchase method for computation of book profit under s.115JB, directing the AO to delete adjustments and allow amortisation/depreciation on goodwill as reflected in the approved merger scheme and audited financials.
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