https://www.taxtmi.com/caselaws?id=773295 The Gujarat HC held that reopening of assessment proceedings based on disallowance under section 14A read with Rule 8D was invalid. The petitioner-company had already provided details of exempt income and investments during original assessment proceedings, with no disallowance made. The AO's notice for reopening was based solely on verification of profit and loss account and balance sheet without any fresh tangible material. The court ruled that reopening assessment on mere change of opinion amounts to impermissible review of the original assessment order passed under section 143(3) on the same facts. Decision favored the assessee. en-us Thu, 08 May 2025 00:00:00 +0530 Wed, 18 Jun 2025 17:16:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773295 The Gujarat HC held that reopening of assessment proceedings based on disallowance under section 14A read with Rule 8D was invalid. The petitioner-company had already provided details of exempt income and investments during original assessment proceedings, with no disallowance made. The AO's notice for reopening was based solely on verification of profit and loss account and balance sheet without any fresh tangible material. The court ruled that reopening assessment on mere change of opinion amounts to impermissible review of the original assessment order passed under section 143(3) on the same facts. Decision favored the assessee. Case-Laws Income Tax Thu, 08 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773295