https://www.taxtmi.com/caselaws?id=762462 The HC held that reassessment proceedings cannot be initiated on change of opinion despite 1998 amendment to Section 147. The petitioner's deduction under Section 54B for agricultural land sold by brothers was initially accepted by AO during original assessment proceedings. Though AO did not record reasons for accepting the explanation, the HC found that AO had applied mind and formed an opinion on the issue. Since the matter was already considered and decided, reopening assessment constituted impermissible change of opinion. The notice under Section 148 for AY 2009-10 and order rejecting objections were quashed. WP allowed. en-us Thu, 14 Nov 2024 00:00:00 +0530 Mon, 02 Dec 2024 08:53:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762462 The HC held that reassessment proceedings cannot be initiated on change of opinion despite 1998 amendment to Section 147. The petitioner's deduction under Section 54B for agricultural land sold by brothers was initially accepted by AO during original assessment proceedings. Though AO did not record reasons for accepting the explanation, the HC found that AO had applied mind and formed an opinion on the issue. Since the matter was already considered and decided, reopening assessment constituted impermissible change of opinion. The notice under Section 148 for AY 2009-10 and order rejecting objections were quashed. WP allowed. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762462