https://www.taxtmi.com/caselaws?id=450942 ITAT Raipur ruled in favor of the assessee, holding that the AO wrongly reopened assessment under Section 147 after four years based on mere change of opinion. The tribunal found that the original AO had already deliberated on the assessee's Section 80IA deduction claim and depreciation matters during the original assessment under Section 143(3). No fresh material or information justified reopening the concluded assessment. The assessee had fully disclosed all material facts, making the case ineligible for extended limitation period under first proviso to Section 147. The reopening was struck down as impermissible. en-us Wed, 13 Mar 2024 00:00:00 +0530 Fri, 15 Mar 2024 12:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450942 ITAT Raipur ruled in favor of the assessee, holding that the AO wrongly reopened assessment under Section 147 after four years based on mere change of opinion. The tribunal found that the original AO had already deliberated on the assessee's Section 80IA deduction claim and depreciation matters during the original assessment under Section 143(3). No fresh material or information justified reopening the concluded assessment. The assessee had fully disclosed all material facts, making the case ineligible for extended limitation period under first proviso to Section 147. The reopening was struck down as impermissible. Case-Laws Income Tax Wed, 13 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450942