https://www.taxtmi.com/caselaws?id=775230 The ITAT Mumbai held that reopening of assessment under section 147 was invalid where the AO had already examined and accepted the assessee's claim for "Claim Right Liability" deduction of Rs. 400 crores during original assessment proceedings under section 143(3). The AO had specifically queried this expenditure through notice under section 142(1), received detailed justifications, conducted personal hearings, and ultimately accepted the claim in the assessment order. The reopening was based on the same material previously considered, without any fresh tangible evidence. The ITAT ruled that forming a different view on identical material constitutes impermissible change of opinion under section 147, making the reassessment proceedings invalid and without jurisdiction. The assessee's appeal was allowed, and the reopening was quashed for lack of new material and being based solely on change of opinion. en-us Fri, 18 Jul 2025 00:00:00 +0530 Tue, 22 Jul 2025 08:25:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775230 The ITAT Mumbai held that reopening of assessment under section 147 was invalid where the AO had already examined and accepted the assessee's claim for "Claim Right Liability" deduction of Rs. 400 crores during original assessment proceedings under section 143(3). The AO had specifically queried this expenditure through notice under section 142(1), received detailed justifications, conducted personal hearings, and ultimately accepted the claim in the assessment order. The reopening was based on the same material previously considered, without any fresh tangible evidence. The ITAT ruled that forming a different view on identical material constitutes impermissible change of opinion under section 147, making the reassessment proceedings invalid and without jurisdiction. The assessee's appeal was allowed, and the reopening was quashed for lack of new material and being based solely on change of opinion. Case-Laws Income Tax Fri, 18 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775230