https://www.taxtmi.com/caselaws?id=449316 The Bombay HC held that reopening of assessment after 4 years was invalid where the AO's reasons were based on details already available in assessment records. The court found that interest income capitalization and tax provision claims were considered during original assessment proceedings, as evidenced by the AO raising queries and the assessee responding. Following Aroni Commercials Ltd., the court ruled that specific discussion in the assessment order is not required if issues were considered during proceedings. The reopening constituted merely a change of opinion rather than valid reasons to believe income escaped assessment. The petition was decided in favor of the assessee. en-us Mon, 05 Feb 2024 00:00:00 +0530 Thu, 08 Feb 2024 17:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449316 The Bombay HC held that reopening of assessment after 4 years was invalid where the AO's reasons were based on details already available in assessment records. The court found that interest income capitalization and tax provision claims were considered during original assessment proceedings, as evidenced by the AO raising queries and the assessee responding. Following Aroni Commercials Ltd., the court ruled that specific discussion in the assessment order is not required if issues were considered during proceedings. The reopening constituted merely a change of opinion rather than valid reasons to believe income escaped assessment. The petition was decided in favor of the assessee. Case-Laws Income Tax Mon, 05 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449316