https://www.taxtmi.com/highlights?id=75759 Reopening of assessment u/s 147 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the petitioner had adequately addressed the AO's queries regarding the deduction claim during the original assessment. Additionally, the court noted that the petitioner had not claimed any deduction for rural advances, contradicting the basis for the alleged escapement of income. - The court deemed the reopening of the assessment as a clear case of change of opinion by the AO, which did not justify reassessment. en-us Sat, 16 Mar 2024 08:41:29 +0530 Sat, 16 Mar 2024 08:41:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=75759 Reopening of assessment u/s 147 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the petitioner had adequately addressed the AO's queries regarding the deduction claim during the original assessment. Additionally, the court noted that the petitioner had not claimed any deduction for rural advances, contradicting the basis for the alleged escapement of income. - The court deemed the reopening of the assessment as a clear case of change of opinion by the AO, which did not justify reassessment. Highlights Income Tax Sat, 16 Mar 2024 08:41:29 +0530 https://www.taxtmi.com/highlights?id=75759