https://www.taxtmi.com/caselaws?id=450950 Bombay HC held that reopening of assessment u/s 147 was invalid as it was based on change of opinion. The AO had during original assessment proceedings specifically queried the petitioner about deduction claimed u/s 36(1)(viia) and received detailed submissions. Petitioner clarified it claimed only 7.5% deduction on total income without claiming rural advances deduction. Since the issue was actively considered during original assessment and AO was satisfied with petitioner's explanation, reopening based on subsequent change of opinion after Catholic Syrian Bank judgment was impermissible. Court ruled in favor of assessee. en-us Thu, 07 Mar 2024 00:00:00 +0530 Tue, 10 Jun 2025 13:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450950 Bombay HC held that reopening of assessment u/s 147 was invalid as it was based on change of opinion. The AO had during original assessment proceedings specifically queried the petitioner about deduction claimed u/s 36(1)(viia) and received detailed submissions. Petitioner clarified it claimed only 7.5% deduction on total income without claiming rural advances deduction. Since the issue was actively considered during original assessment and AO was satisfied with petitioner's explanation, reopening based on subsequent change of opinion after Catholic Syrian Bank judgment was impermissible. Court ruled in favor of assessee. Case-Laws Income Tax Thu, 07 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450950