https://www.taxtmi.com/caselaws?id=344462 Reopening under sections 147 and 148 was unsustainable where the deduction claim under section 10B had been specifically examined in the original scrutiny assessment, supported by detailed replies and documents, and accepted substantially on merits. The proposed disallowance under section 14A read with Rule 8D was also already considered and adjusted in the original assessment. On these facts, issuing a reassessment notice on the same material amounted to a mere change of opinion, which is impermissible. The reassessment notice was therefore liable to be quashed in favour of the assessee. en-us Mon, 12 Jun 2017 00:00:00 +0530 Sat, 17 Jun 2017 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344462 Reopening under sections 147 and 148 was unsustainable where the deduction claim under section 10B had been specifically examined in the original scrutiny assessment, supported by detailed replies and documents, and accepted substantially on merits. The proposed disallowance under section 14A read with Rule 8D was also already considered and adjusted in the original assessment. On these facts, issuing a reassessment notice on the same material amounted to a mere change of opinion, which is impermissible. The reassessment notice was therefore liable to be quashed in favour of the assessee. Case-Laws Income Tax Mon, 12 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344462