https://www.taxtmi.com/caselaws?id=456735 Reassessment under Section 147 read with Section 148 was invalid where the deduction claim under Section 80P(2)(d) had already been examined in the original scrutiny assessment. The assessee had disclosed the relevant interest income and Chapter VI-A deductions in its return and replies under Section 142(1), and the assessment record showed that the issue was considered before the original assessment was completed. In the absence of any fresh tangible material, reopening on the same material amounted to a mere change of opinion, which is impermissible. The reopening notice and the order disposing of objections were therefore set aside. en-us Mon, 11 Sep 2023 00:00:00 +0530 Sat, 10 Aug 2024 18:36:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456735 Reassessment under Section 147 read with Section 148 was invalid where the deduction claim under Section 80P(2)(d) had already been examined in the original scrutiny assessment. The assessee had disclosed the relevant interest income and Chapter VI-A deductions in its return and replies under Section 142(1), and the assessment record showed that the issue was considered before the original assessment was completed. In the absence of any fresh tangible material, reopening on the same material amounted to a mere change of opinion, which is impermissible. The reopening notice and the order disposing of objections were therefore set aside. Case-Laws Income Tax Mon, 11 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456735