https://www.taxtmi.com/caselaws?id=445346 HC held that reopening of assessment under Section 147 based on change of opinion is impermissible. The assessing officer had previously examined the assessee's bad debt claims under Sections 36(1)(vii), 36(1)(viia), and 36(1)(viii) during original assessment proceedings, issuing notices and questionnaires which were duly answered. The assessee had disclosed all material facts. The reason to believe income escaped assessment was merely based on giving effect to CIT(A)'s order, constituting only a change of opinion rather than valid grounds for reopening. The petition was decided in favor of the assessee. en-us Tue, 31 Oct 2023 00:00:00 +0530 Mon, 06 Nov 2023 10:36:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445346 HC held that reopening of assessment under Section 147 based on change of opinion is impermissible. The assessing officer had previously examined the assessee's bad debt claims under Sections 36(1)(vii), 36(1)(viia), and 36(1)(viii) during original assessment proceedings, issuing notices and questionnaires which were duly answered. The assessee had disclosed all material facts. The reason to believe income escaped assessment was merely based on giving effect to CIT(A)'s order, constituting only a change of opinion rather than valid grounds for reopening. The petition was decided in favor of the assessee. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445346