https://www.taxtmi.com/caselaws?id=64318 The ITAT Delhi-C held that the reassessment proceedings initiated under sections 147 and 148 of the IT Act were invalid as they were based on a change of opinion and not valid grounds. The tribunal emphasized that reassessment cannot be solely triggered by a change of opinion and must adhere to legal requirements. Additionally, deductions under sections 80HH and 80-I were partially allowed by the CIT(A) but were further contested by the assessee, with the ITAT upholding some decisions while rejecting others based on prior tribunal rulings. The reassessment directed by a superior authority, not the AO's satisfaction, was deemed jurisdictionally invalid by the ITAT, emphasizing the importance of statutory compliance in such proceedings. en-us Fri, 30 Jan 2004 00:00:00 +0530 Mon, 07 Feb 2011 11:28:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64318 The ITAT Delhi-C held that the reassessment proceedings initiated under sections 147 and 148 of the IT Act were invalid as they were based on a change of opinion and not valid grounds. The tribunal emphasized that reassessment cannot be solely triggered by a change of opinion and must adhere to legal requirements. Additionally, deductions under sections 80HH and 80-I were partially allowed by the CIT(A) but were further contested by the assessee, with the ITAT upholding some decisions while rejecting others based on prior tribunal rulings. The reassessment directed by a superior authority, not the AO's satisfaction, was deemed jurisdictionally invalid by the ITAT, emphasizing the importance of statutory compliance in such proceedings. Case-Laws Income Tax Fri, 30 Jan 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64318