https://www.taxtmi.com/caselaws?id=329275 The court upheld the Tribunal's decision regarding the validity of re-opening the assessment under section 147 of the Income Tax Act, 1961. It emphasized that assessments cannot be re-opened solely on a change of opinion, as once the Assessing Officer scrutinizes a claim during assessment and does not reject it, the claim is deemed allowed. The court concluded that the Assessing Officer had formed an opinion on the claim, even if reasons were not explicitly provided in the assessment order. Additionally, the court affirmed the Tribunal's decision on the disallowance of a provision for damaged goods, stating that the Assessing Officer's acceptance of the claim during the original assessment indicated the formation of an opinion, precluding the need for disallowance in the re-assessment. en-us Tue, 21 Jun 2016 00:00:00 +0530 Mon, 27 Jun 2016 07:23:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=329275 The court upheld the Tribunal's decision regarding the validity of re-opening the assessment under section 147 of the Income Tax Act, 1961. It emphasized that assessments cannot be re-opened solely on a change of opinion, as once the Assessing Officer scrutinizes a claim during assessment and does not reject it, the claim is deemed allowed. The court concluded that the Assessing Officer had formed an opinion on the claim, even if reasons were not explicitly provided in the assessment order. Additionally, the court affirmed the Tribunal's decision on the disallowance of a provision for damaged goods, stating that the Assessing Officer's acceptance of the claim during the original assessment indicated the formation of an opinion, precluding the need for disallowance in the re-assessment. Case-Laws Income Tax Tue, 21 Jun 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=329275