https://www.taxtmi.com/caselaws?id=422013 The Tribunal invalidated the reopening of assessment under Section 147 of the Income Tax Act, citing that it amounted to a review rather than reassessment, which is impermissible. The reassessment order was quashed. The issue of disallowance of interest under Section 36(1)(iii) became moot due to the quashing of the reassessment. The Tribunal did not address the disallowance under Section 14A due to the same reason. The assessee's appeal was allowed, and the Revenue's appeal was dismissed as academic, emphasizing that reopening assessments based on a mere change of opinion is not allowed. en-us Wed, 13 Apr 2022 00:00:00 +0530 Thu, 05 May 2022 11:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=422013 The Tribunal invalidated the reopening of assessment under Section 147 of the Income Tax Act, citing that it amounted to a review rather than reassessment, which is impermissible. The reassessment order was quashed. The issue of disallowance of interest under Section 36(1)(iii) became moot due to the quashing of the reassessment. The Tribunal did not address the disallowance under Section 14A due to the same reason. The assessee's appeal was allowed, and the Revenue's appeal was dismissed as academic, emphasizing that reopening assessments based on a mere change of opinion is not allowed. Case-Laws Income Tax Wed, 13 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=422013