https://www.taxtmi.com/caselaws?id=771784 Gujarat HC held that reopening of assessment under section 147 was invalid as it was based on change of opinion rather than valid reason to believe. The petitioner had provided complete TDS details during original assessment, and the AO erroneously considered only partial information regarding advertisement and professional fees while ignoring other TDS deductions. Regarding section 80IC deduction, the loss adjustment issue was already considered during regular assessment proceedings, making the reopening merely a review rather than genuine escapement of income. The court emphasized that reopening is not equivalent to review of assessment order, following Supreme Court precedent in Kelvinator case. Assessment reopening was quashed in favor of the assessee. en-us Tue, 18 Mar 2025 00:00:00 +0530 Fri, 30 May 2025 08:55:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771784 Gujarat HC held that reopening of assessment under section 147 was invalid as it was based on change of opinion rather than valid reason to believe. The petitioner had provided complete TDS details during original assessment, and the AO erroneously considered only partial information regarding advertisement and professional fees while ignoring other TDS deductions. Regarding section 80IC deduction, the loss adjustment issue was already considered during regular assessment proceedings, making the reopening merely a review rather than genuine escapement of income. The court emphasized that reopening is not equivalent to review of assessment order, following Supreme Court precedent in Kelvinator case. Assessment reopening was quashed in favor of the assessee. Case-Laws Income Tax Tue, 18 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771784