https://www.taxtmi.com/caselaws?id=300736 Exemption under section 10B, or alternatively section 10A, was treated as available where the assessee was approved by STPI as a 100% export-oriented unit and the claim had been consistently accepted in earlier years without any change in facts or law. Reassessment under section 147 was treated as invalid where it was based on the same material considered in the original assessment, with no fresh tangible material to justify reopening, as this amounted to a change of opinion. The respondent was also permitted under rule 27 to support the order on the ground of invalid reopening, and that objection was entertained. en-us Wed, 24 Feb 2021 00:00:00 +0530 Sat, 12 Mar 2022 13:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300736 Exemption under section 10B, or alternatively section 10A, was treated as available where the assessee was approved by STPI as a 100% export-oriented unit and the claim had been consistently accepted in earlier years without any change in facts or law. Reassessment under section 147 was treated as invalid where it was based on the same material considered in the original assessment, with no fresh tangible material to justify reopening, as this amounted to a change of opinion. The respondent was also permitted under rule 27 to support the order on the ground of invalid reopening, and that objection was entertained. Case-Laws Income Tax Wed, 24 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300736