https://www.taxtmi.com/caselaws?id=313462 ITAT Mumbai held that the reopening of assessment under section 147 was invalid on two grounds. First, the satisfaction for issuing notice under section 148 was recorded by Additional CIT instead of the prescribed authority under section 151(1), making the notice invalid. Second, the AO reopened assessment merely on change of opinion regarding section 80IB(10) deduction eligibility without any tangible material showing income escapement, which constituted impermissible review of original assessment. The assessment order was quashed and decided in favor of assessee. en-us Fri, 02 Feb 2018 00:00:00 +0530 Tue, 16 Apr 2024 20:37:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313462 ITAT Mumbai held that the reopening of assessment under section 147 was invalid on two grounds. First, the satisfaction for issuing notice under section 148 was recorded by Additional CIT instead of the prescribed authority under section 151(1), making the notice invalid. Second, the AO reopened assessment merely on change of opinion regarding section 80IB(10) deduction eligibility without any tangible material showing income escapement, which constituted impermissible review of original assessment. The assessment order was quashed and decided in favor of assessee. Case-Laws Income Tax Fri, 02 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313462