https://www.taxtmi.com/highlights?id=67639 Reopening of assessment u/s 147 - change of opinion - The Assessing Officer simply has accorded a fresh consideration and come to a conclusion that the assessee ought to have claimed benefit of deduction under section 35ABB which would have resulted in reducing the allowance under section 32 - In the absence of any tangible material, the present case is nothing but a case of change of opinion and thus does not satisfy the jurisdictional foundation under section 147 of the Act. - HC en-us Wed, 11 Jan 2023 12:42:19 +0530 Wed, 11 Jan 2023 12:42:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=67639 Reopening of assessment u/s 147 - change of opinion - The Assessing Officer simply has accorded a fresh consideration and come to a conclusion that the assessee ought to have claimed benefit of deduction under section 35ABB which would have resulted in reducing the allowance under section 32 - In the absence of any tangible material, the present case is nothing but a case of change of opinion and thus does not satisfy the jurisdictional foundation under section 147 of the Act. - HC Highlights Income Tax Wed, 11 Jan 2023 12:42:19 +0530 https://www.taxtmi.com/highlights?id=67639