https://www.taxtmi.com/caselaws?id=460824 The Bombay HC quashed reassessment proceedings initiated u/s 147 within four years. The AO alleged double deduction of four items (Inventories, Sundry Debtors, Loans Advances, and Cost of Set Top Boxes) that were reduced from Share Premium Account and claimed as deduction in income computation. The petitioner objected, stating no double deduction occurred. The AO failed to rebut this objection and accepted items weren't charged to profit and loss account. The HC found no justification for double deduction claim since items were balance sheet entries, not profit and loss account debits. Following Aroni Commercials Limited precedent, the HC held reopening constituted impermissible change of opinion where issues were previously examined. Notice u/s 148 was set aside in favor of assessee. en-us Tue, 20 Feb 2024 00:00:00 +0530 Sat, 22 Feb 2025 18:13:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460824 The Bombay HC quashed reassessment proceedings initiated u/s 147 within four years. The AO alleged double deduction of four items (Inventories, Sundry Debtors, Loans Advances, and Cost of Set Top Boxes) that were reduced from Share Premium Account and claimed as deduction in income computation. The petitioner objected, stating no double deduction occurred. The AO failed to rebut this objection and accepted items weren't charged to profit and loss account. The HC found no justification for double deduction claim since items were balance sheet entries, not profit and loss account debits. Following Aroni Commercials Limited precedent, the HC held reopening constituted impermissible change of opinion where issues were previously examined. Notice u/s 148 was set aside in favor of assessee. Case-Laws Income Tax Tue, 20 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460824