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    <title>2025 (6) TMI 1313 - ITAT CHANDIGARH</title>
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    <description>ITAT Chandigarh quashed the reopening of assessment proceedings initiated by the AO. The revenue sought to deny Section 80-IB(10) deduction claiming the project was incomplete by the statutory deadline. The tribunal held that reopening was impermissible as it constituted a mere change of opinion on existing material without any fresh tangible evidence. The AO had already examined the same facts during original assessment under Section 143(3) and raised specific queries which were duly answered. Following Supreme Court precedents in Kelvinator and Marico cases, the tribunal ruled that review of assessment under the guise of reopening amounts to abuse of power when based on previously available information. The assessee&#039;s appeal was allowed.</description>
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    <pubDate>Mon, 16 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1313 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=773200</link>
      <description>ITAT Chandigarh quashed the reopening of assessment proceedings initiated by the AO. The revenue sought to deny Section 80-IB(10) deduction claiming the project was incomplete by the statutory deadline. The tribunal held that reopening was impermissible as it constituted a mere change of opinion on existing material without any fresh tangible evidence. The AO had already examined the same facts during original assessment under Section 143(3) and raised specific queries which were duly answered. Following Supreme Court precedents in Kelvinator and Marico cases, the tribunal ruled that review of assessment under the guise of reopening amounts to abuse of power when based on previously available information. The assessee&#039;s appeal was allowed.</description>
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      <pubDate>Mon, 16 Jun 2025 00:00:00 +0530</pubDate>
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