https://www.taxtmi.com/caselaws?id=764577 ITAT Chennai held that reassessment proceedings under Section 148 were invalid as the AO had already examined TDS issues during original assessment under Section 143(2), constituting impermissible change of opinion rather than valid reopening. The tribunal quashed reassessment proceedings as void ab initio. On substantive issues, ITAT allowed depreciation at 60% on UPS, sustained disallowance of projector depreciation, confirmed allowance of payments to motor vehicle dealers, deleted UPR addition to book profits under Section 115JB, sustained addition of long-term policy premiums, allowed 60% depreciation on computer software, permitted IBNR/IBNER provisions as ascertained liabilities, held Section 14A inapplicable to insurance companies, and remanded UPR disallowance for fresh consideration while dismissing education cess deduction claims. en-us Wed, 08 Jan 2025 00:00:00 +0530 Mon, 09 Jun 2025 14:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764577 ITAT Chennai held that reassessment proceedings under Section 148 were invalid as the AO had already examined TDS issues during original assessment under Section 143(2), constituting impermissible change of opinion rather than valid reopening. The tribunal quashed reassessment proceedings as void ab initio. On substantive issues, ITAT allowed depreciation at 60% on UPS, sustained disallowance of projector depreciation, confirmed allowance of payments to motor vehicle dealers, deleted UPR addition to book profits under Section 115JB, sustained addition of long-term policy premiums, allowed 60% depreciation on computer software, permitted IBNR/IBNER provisions as ascertained liabilities, held Section 14A inapplicable to insurance companies, and remanded UPR disallowance for fresh consideration while dismissing education cess deduction claims. Case-Laws Income Tax Wed, 08 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764577