https://www.taxtmi.com/caselaws?id=121401 The Tribunal upheld the validity of proceedings initiated under section 147, rejecting the CIT(A)'s view that it was based on a "change of opinion." The Tribunal found the Assessing Officer had not considered the DEPB issue initially, justifying the reopening. Additionally, the Tribunal deemed the reopening to disallow deductions under section 80HHC on DEPB receipts valid, based on a Board's Circular and subsequent legal amendments. Regarding jurisdiction, the Tribunal held the Assessing Officer could reassess despite a pending appeal, as the issues differed. The Tribunal allowed the Revenue's appeal, setting aside the CIT(A)'s order and remanding for further consideration. en-us Tue, 26 May 2009 00:00:00 +0530 Mon, 30 Jul 2012 14:08:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=121401 The Tribunal upheld the validity of proceedings initiated under section 147, rejecting the CIT(A)'s view that it was based on a "change of opinion." The Tribunal found the Assessing Officer had not considered the DEPB issue initially, justifying the reopening. Additionally, the Tribunal deemed the reopening to disallow deductions under section 80HHC on DEPB receipts valid, based on a Board's Circular and subsequent legal amendments. Regarding jurisdiction, the Tribunal held the Assessing Officer could reassess despite a pending appeal, as the issues differed. The Tribunal allowed the Revenue's appeal, setting aside the CIT(A)'s order and remanding for further consideration. Case-Laws Income Tax Tue, 26 May 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=121401