https://www.taxtmi.com/caselaws?id=313477 ITAT Chennai dismissed Revenue's appeal against CIT(A)'s order cancelling reopening beyond four years under section 147, finding no failure by assessee to disclose material facts during original assessment under section 143(3). The tribunal upheld CIT(A)'s enhancement power regarding section 36(1)(viia) deduction, confirming that deduction for bad debts cannot exceed provisions made in books of accounts, following Punjab & Haryana HC and Karnataka HC precedents. ITAT validated notice under section 143(2) as within limitation and upheld reopening validity where income escaped assessment due to excess deduction claims. However, tribunal allowed assessee's appeal on section 154 rectification, holding the issue was debatable and beyond scope of mistake apparent from record. en-us Wed, 18 Oct 2023 00:00:00 +0530 Tue, 16 Apr 2024 20:37:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313477 ITAT Chennai dismissed Revenue's appeal against CIT(A)'s order cancelling reopening beyond four years under section 147, finding no failure by assessee to disclose material facts during original assessment under section 143(3). The tribunal upheld CIT(A)'s enhancement power regarding section 36(1)(viia) deduction, confirming that deduction for bad debts cannot exceed provisions made in books of accounts, following Punjab & Haryana HC and Karnataka HC precedents. ITAT validated notice under section 143(2) as within limitation and upheld reopening validity where income escaped assessment due to excess deduction claims. However, tribunal allowed assessee's appeal on section 154 rectification, holding the issue was debatable and beyond scope of mistake apparent from record. Case-Laws Income Tax Wed, 18 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313477