Reopening an assessment due to change of opinion is invalid if covered u/ss 143(3) or 263 of Income Tax Act.

Reopening an assessment due to change of opinion is invalid if covered u/ss 143(3) or 263 of Income Tax Act. https://www.taxtmi.com/highlights?id=54065 Validity of Reopening of assessment - change of opinion - If the very same reasons were the subject matter of the proceedings under Section 143(3) of the Act or the proceedings under Section 263 of the Act, once again, for the very same reasons, the power under Section 147 cannot be invoked and having done so, the CIT(A) as well as the Tribunal were right in coming to the conclusion that the reopening was bad in law. en-us Fri, 17 Jul 2020 11:45:59 +0530 Fri, 17 Jul 2020 11:45:59 +0530 TaxTMI RSS Generator Reopening an assessment due to change of opinion is invalid if covered u/ss 143(3) or 263 of Income Tax Act. https://www.taxtmi.com/highlights?id=54065 Validity of Reopening of assessment - change of opinion - If the very same reasons were the subject matter of the proceedings under Section 143(3) of the Act or the proceedings under Section 263 of the Act, once again, for the very same reasons, the power under Section 147 cannot be invoked and having done so, the CIT(A) as well as the Tribunal were right in coming to the conclusion that the reopening was bad in law. Highlights Income Tax Fri, 17 Jul 2020 11:45:59 +0530 https://www.taxtmi.com/highlights?id=54065