https://www.taxtmi.com/caselaws?id=355671 ITAT MUMBAI held for the assessee that reopening under sections 147/148 was invalid because the AO had examined and allowed the section 80IC deduction in the original assessment framed u/s 143(3), including consideration of a revised return; reopening cannot substitute for review or effect a mere change of opinion. The Tribunal noted a Bombay HC decision supporting this principle and found no jurisdictional basis to reassess, deciding in favour of the assessee. en-us Mon, 12 Feb 2018 00:00:00 +0530 Mon, 01 Sep 2025 11:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=355671 ITAT MUMBAI held for the assessee that reopening under sections 147/148 was invalid because the AO had examined and allowed the section 80IC deduction in the original assessment framed u/s 143(3), including consideration of a revised return; reopening cannot substitute for review or effect a mere change of opinion. The Tribunal noted a Bombay HC decision supporting this principle and found no jurisdictional basis to reassess, deciding in favour of the assessee. Case-Laws Income Tax Mon, 12 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=355671