https://www.taxtmi.com/caselaws?id=752299 The Bombay HC quashed reassessment proceedings initiated by the AO within four years of the relevant assessment year. The court found that the AO's reasons to believe were based on a change of opinion rather than tangible material indicating escaped income. Two items were challenged: designing fees expenses and concession fees paid to PUDA, both previously accepted during original assessment after detailed scrutiny. The AO later sought to capitalize these expenses instead of allowing them as revenue deductions. Since the assessee had provided all required details during original proceedings and the items were duly considered, the court held this constituted impermissible change of opinion, not valid grounds for reopening. The petition was allowed in favor of the assessee. en-us Tue, 30 Apr 2024 00:00:00 +0530 Tue, 07 May 2024 07:29:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752299 The Bombay HC quashed reassessment proceedings initiated by the AO within four years of the relevant assessment year. The court found that the AO's reasons to believe were based on a change of opinion rather than tangible material indicating escaped income. Two items were challenged: designing fees expenses and concession fees paid to PUDA, both previously accepted during original assessment after detailed scrutiny. The AO later sought to capitalize these expenses instead of allowing them as revenue deductions. Since the assessee had provided all required details during original proceedings and the items were duly considered, the court held this constituted impermissible change of opinion, not valid grounds for reopening. The petition was allowed in favor of the assessee. Case-Laws Income Tax Tue, 30 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752299