https://www.taxtmi.com/caselaws?id=445094 ITAT RAIPUR held that deductions treated as performance guarantees/deposits were refundable deposits and should have been shown as assets; however, reopening under s.147/s.143(3) was quashed because the A.O. relied solely on a change of opinion without any fresh material or information after conclusion of the original assessment. In absence of new tangible evidence indicating escaped income, the reassessment was invalid for lack of jurisdiction. Decision: assessment under s.143(3)/147 quashed and matter decided in favour of the assessee. en-us Fri, 27 Oct 2023 00:00:00 +0530 Sat, 11 Oct 2025 13:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445094 ITAT RAIPUR held that deductions treated as performance guarantees/deposits were refundable deposits and should have been shown as assets; however, reopening under s.147/s.143(3) was quashed because the A.O. relied solely on a change of opinion without any fresh material or information after conclusion of the original assessment. In absence of new tangible evidence indicating escaped income, the reassessment was invalid for lack of jurisdiction. Decision: assessment under s.143(3)/147 quashed and matter decided in favour of the assessee. Case-Laws Income Tax Fri, 27 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445094