https://www.taxtmi.com/caselaws?id=750657 ITAT Mumbai held that reopening of assessment under section 147 after four years was invalid where AO sought to deny section 80IB(10) deduction for housing project. The original AO had examined and accepted the deduction claim after due verification. The reopening AO relied solely on existing assessment records without any new tangible material, constituting impermissible review rather than reassessment. Following CIT v. Kelvinator of India Ltd., the tribunal ruled that reopening based on mere change of opinion without fresh evidence amounts to review, which AO lacks power to conduct. Assessment reopening quashed in assessee's favor. en-us Fri, 22 Mar 2024 00:00:00 +0530 Tue, 26 Mar 2024 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750657 ITAT Mumbai held that reopening of assessment under section 147 after four years was invalid where AO sought to deny section 80IB(10) deduction for housing project. The original AO had examined and accepted the deduction claim after due verification. The reopening AO relied solely on existing assessment records without any new tangible material, constituting impermissible review rather than reassessment. Following CIT v. Kelvinator of India Ltd., the tribunal ruled that reopening based on mere change of opinion without fresh evidence amounts to review, which AO lacks power to conduct. Assessment reopening quashed in assessee's favor. Case-Laws Income Tax Fri, 22 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750657