https://www.taxtmi.com/caselaws?id=755560 The ITAT Patna upheld the validity of assessment reopening where the assessee claimed excess deduction for bad and doubtful debts under section 36(1)(viia). The tribunal found that the excess claim was apparent from records and constituted clear income escapement, not a change of opinion. The AO had tangible material in assessment records showing the assessee exceeded the statutory 7.5% limit for such deductions. The tribunal emphasized that statutory provisions allowed only one interpretation regarding the deduction limit, making no second opinion possible. The assessee's appeal was dismissed as lacking merit. en-us Thu, 11 Jul 2024 00:00:00 +0530 Sat, 13 Jul 2024 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755560 The ITAT Patna upheld the validity of assessment reopening where the assessee claimed excess deduction for bad and doubtful debts under section 36(1)(viia). The tribunal found that the excess claim was apparent from records and constituted clear income escapement, not a change of opinion. The AO had tangible material in assessment records showing the assessee exceeded the statutory 7.5% limit for such deductions. The tribunal emphasized that statutory provisions allowed only one interpretation regarding the deduction limit, making no second opinion possible. The assessee's appeal was dismissed as lacking merit. Case-Laws Income Tax Thu, 11 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755560