https://www.taxtmi.com/highlights?id=71641 Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not discover even with due diligence, the petitioner cannot be blamed for that. If the AO did not examine the issue of allowability of the deduction during the course of regular assessment, the revenue has no jurisdiction to reopen the assessment. - HC en-us Thu, 24 Aug 2023 17:43:02 +0530 Thu, 24 Aug 2023 17:43:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=71641 Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not discover even with due diligence, the petitioner cannot be blamed for that. If the AO did not examine the issue of allowability of the deduction during the course of regular assessment, the revenue has no jurisdiction to reopen the assessment. - HC Highlights Income Tax Thu, 24 Aug 2023 17:43:02 +0530 https://www.taxtmi.com/highlights?id=71641