https://www.taxtmi.com/caselaws?id=460094 ITAT Jaipur held that reopening of assessment u/s 147 for disallowing deduction u/s 80IA on interest income and penal interest was invalid. The assessee, engaged in developing industrial parks, received interest from allottees for late payments and other maintenance-related income. Since AO had allowed the deduction in original assessment u/s 143(3) and first reassessment, and the issue permitted two possible views, reopening without fresh material constituted impermissible change of opinion. The interest income was connected to business activity of developing and maintaining industrial parks, making it eligible for deduction. Reassessment was quashed. en-us Fri, 09 Feb 2018 00:00:00 +0530 Fri, 10 Jan 2025 20:17:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460094 ITAT Jaipur held that reopening of assessment u/s 147 for disallowing deduction u/s 80IA on interest income and penal interest was invalid. The assessee, engaged in developing industrial parks, received interest from allottees for late payments and other maintenance-related income. Since AO had allowed the deduction in original assessment u/s 143(3) and first reassessment, and the issue permitted two possible views, reopening without fresh material constituted impermissible change of opinion. The interest income was connected to business activity of developing and maintaining industrial parks, making it eligible for deduction. Reassessment was quashed. Case-Laws Income Tax Fri, 09 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460094