https://www.taxtmi.com/caselaws?id=464252 ITAT, Mumbai held that reopening under s.147 was invalid where AO had already applied his mind and concluded the issue during original assessment under s.143(3); issuing notice under s.142(1) and reopening on the same contention would amount to impermissible change of opinion. The additions seeking disallowance under s.36(1)(viia) were set aside and the appeal of the assessee allowed. en-us Mon, 30 Sep 2024 00:00:00 +0530 Tue, 14 Oct 2025 19:08:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464252 ITAT, Mumbai held that reopening under s.147 was invalid where AO had already applied his mind and concluded the issue during original assessment under s.143(3); issuing notice under s.142(1) and reopening on the same contention would amount to impermissible change of opinion. The additions seeking disallowance under s.36(1)(viia) were set aside and the appeal of the assessee allowed. Case-Laws Income Tax Mon, 30 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464252