https://www.taxtmi.com/caselaws?id=216245 The HC held that reopening the assessment to deny exemption u/s 10(23G) was invalid as it amounted to a mere change of opinion. The AO had originally considered the assessee's claims regarding interest from bonds and capital gains, examined the details, and disallowed expenditure partly but did not reject the exemption outright. The AO's reasons for reopening relied solely on the same material already on record, which does not justify reopening. Consequently, the notice for reopening was issued without jurisdiction, and the HC ruled in favor of the assessee. en-us Mon, 30 Jul 2012 00:00:00 +0530 Wed, 13 Aug 2025 17:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216245 The HC held that reopening the assessment to deny exemption u/s 10(23G) was invalid as it amounted to a mere change of opinion. The AO had originally considered the assessee's claims regarding interest from bonds and capital gains, examined the details, and disallowed expenditure partly but did not reject the exemption outright. The AO's reasons for reopening relied solely on the same material already on record, which does not justify reopening. Consequently, the notice for reopening was issued without jurisdiction, and the HC ruled in favor of the assessee. Case-Laws Income Tax Mon, 30 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216245