https://www.taxtmi.com/caselaws?id=450327 The Bombay HC held that reopening of assessment under section 147 was invalid as it was based on change of opinion rather than valid reasons to believe. The petitioner successfully demonstrated that all four contested items - provision against unascertained liabilities, excessive deduction under section 35(2AB), CSR expenses and donations deduction, and excess section 80IC allowance - were subject matter of discussion during original assessment proceedings through notices under section 142(1) and subsequent replies. The court ruled that once queries are raised and replied to during assessment, they become subject of AO's consideration regardless of specific mention in assessment order, making reopening impermissible. en-us Mon, 26 Feb 2024 00:00:00 +0530 Fri, 12 Jul 2024 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450327 The Bombay HC held that reopening of assessment under section 147 was invalid as it was based on change of opinion rather than valid reasons to believe. The petitioner successfully demonstrated that all four contested items - provision against unascertained liabilities, excessive deduction under section 35(2AB), CSR expenses and donations deduction, and excess section 80IC allowance - were subject matter of discussion during original assessment proceedings through notices under section 142(1) and subsequent replies. The court ruled that once queries are raised and replied to during assessment, they become subject of AO's consideration regardless of specific mention in assessment order, making reopening impermissible. Case-Laws Income Tax Mon, 26 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450327