https://www.taxtmi.com/caselaws?id=359265 SC held that reopening under s.147 by issuing notice u/s.148 was invalid because the Assessing Officer had already considered how and to what extent deduction under s.10A of the IT Act should be allowed during the original assessment. The show cause notice demonstrated awareness of lack of separate books and how proportional allocation of common expenses should be made, so reassessment was merely a prohibited change of opinion. Matter decided in favour of the assessee. en-us Tue, 24 Apr 2018 00:00:00 +0530 Mon, 27 Oct 2025 11:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=359265 SC held that reopening under s.147 by issuing notice u/s.148 was invalid because the Assessing Officer had already considered how and to what extent deduction under s.10A of the IT Act should be allowed during the original assessment. The show cause notice demonstrated awareness of lack of separate books and how proportional allocation of common expenses should be made, so reassessment was merely a prohibited change of opinion. Matter decided in favour of the assessee. Case-Laws Income Tax Tue, 24 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=359265