https://www.taxtmi.com/caselaws?id=215355 The Tribunal upheld the CIT(A)'s decision to quash the reassessment proceedings under section 147 of the Income Tax Act, emphasizing that reopening an assessment on the same set of facts constitutes a change of opinion, which is not permissible. The Tribunal also affirmed the CIT(A)'s ruling regarding the allocation of depreciation and advertisement expenses between Domestic Tariff Area (DTA) and Export Oriented Unit (EOU) for deduction under section 10B, holding that the original assessment had considered these details and reopening based on a change of opinion was not justified. en-us Fri, 06 Jul 2012 00:00:00 +0530 Mon, 18 Apr 2016 11:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215355 The Tribunal upheld the CIT(A)'s decision to quash the reassessment proceedings under section 147 of the Income Tax Act, emphasizing that reopening an assessment on the same set of facts constitutes a change of opinion, which is not permissible. The Tribunal also affirmed the CIT(A)'s ruling regarding the allocation of depreciation and advertisement expenses between Domestic Tariff Area (DTA) and Export Oriented Unit (EOU) for deduction under section 10B, holding that the original assessment had considered these details and reopening based on a change of opinion was not justified. Case-Laws Income Tax Fri, 06 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215355