https://www.taxtmi.com/caselaws?id=774539 The HC upheld the CIT(Appeals) and ITAT decision invalidating reassessment proceedings under Section 147. The AO sought to reopen assessment claiming the assessee failed to reduce foreign exchange gains from asset cost for depreciation, improperly treated technical know-how payments, and couldn't prove DEPB/duty drawback option choice. The court found the original assessment under Section 143(3) was completed after considering all details, with subsequent Section 154 adjustment for Section 80HHC deduction. The reopening constituted mere change of opinion, not valid reasons to believe, making reassessment invalid. en-us Tue, 01 Jul 2025 00:00:00 +0530 Thu, 10 Jul 2025 08:39:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774539 The HC upheld the CIT(Appeals) and ITAT decision invalidating reassessment proceedings under Section 147. The AO sought to reopen assessment claiming the assessee failed to reduce foreign exchange gains from asset cost for depreciation, improperly treated technical know-how payments, and couldn't prove DEPB/duty drawback option choice. The court found the original assessment under Section 143(3) was completed after considering all details, with subsequent Section 154 adjustment for Section 80HHC deduction. The reopening constituted mere change of opinion, not valid reasons to believe, making reassessment invalid. Case-Laws Income Tax Tue, 01 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774539