https://www.taxtmi.com/caselaws?id=295688 The High Court dismissed the appeal challenging the validity of a reassessment order, finding it to be a mere change of opinion without tangible material supporting income escapement. The Court held that the Assessing Officer's actions indicated a change of opinion rather than a valid reassessment. Additionally, the Court ruled that reopening the assessment based on excessive deduction under Section 80HHC of the Income Tax Act was not justified, citing that an audit opinion cannot be the basis for such reopening. The appeal was dismissed without costs. en-us Mon, 26 Aug 2013 00:00:00 +0530 Tue, 15 Jun 2021 11:58:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=295688 The High Court dismissed the appeal challenging the validity of a reassessment order, finding it to be a mere change of opinion without tangible material supporting income escapement. The Court held that the Assessing Officer's actions indicated a change of opinion rather than a valid reassessment. Additionally, the Court ruled that reopening the assessment based on excessive deduction under Section 80HHC of the Income Tax Act was not justified, citing that an audit opinion cannot be the basis for such reopening. The appeal was dismissed without costs. Case-Laws Income Tax Mon, 26 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=295688