https://www.taxtmi.com/caselaws?id=388683 The ITAT condoned a 41-day delay in filing the appeal, finding no malafide intent. It quashed the reopening of assessment under Sec. 147, ruling it a mere change of opinion based on audit objections, invalid under law. The notice under Sec. 148 was deemed invalid due to lack of independent application of mind by JCIT. The AO's failure to address objections violated established principles. The disallowance of exemption under Sec. 10(23C)(iiiab) was rendered academic as the reopening was quashed. The interest under Sec. 234B was not separately adjudicated. The appeal was allowed, and the proceedings were annulled. en-us Mon, 18 Nov 2019 00:00:00 +0530 Thu, 07 Nov 2024 14:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=388683 The ITAT condoned a 41-day delay in filing the appeal, finding no malafide intent. It quashed the reopening of assessment under Sec. 147, ruling it a mere change of opinion based on audit objections, invalid under law. The notice under Sec. 148 was deemed invalid due to lack of independent application of mind by JCIT. The AO's failure to address objections violated established principles. The disallowance of exemption under Sec. 10(23C)(iiiab) was rendered academic as the reopening was quashed. The interest under Sec. 234B was not separately adjudicated. The appeal was allowed, and the proceedings were annulled. Case-Laws Income Tax Mon, 18 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=388683