https://www.taxtmi.com/caselaws?id=779893 ITAT MUMBAI - AT held that the assessment reopening was invalid and the reassessment objections failed. The AO had examined and accepted the 80IA claim during original assessment based on Form 10CCB and project accounts, so reopening amounted to impermissible change of opinion absent fresh tangible material. The AO's attempt to reduce 80IA profits when computing other Chapter VIA deductions contradicted jurisdictional HC precedent and failed. Treating both 80HHC and 80HHE on same profit was unsustainable, and disallowance of prior-period expenses was not a proper ground to reopen. The reassessment was set aside. en-us Thu, 23 Jan 2025 00:00:00 +0530 Mon, 13 Oct 2025 18:50:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779893 ITAT MUMBAI - AT held that the assessment reopening was invalid and the reassessment objections failed. The AO had examined and accepted the 80IA claim during original assessment based on Form 10CCB and project accounts, so reopening amounted to impermissible change of opinion absent fresh tangible material. The AO's attempt to reduce 80IA profits when computing other Chapter VIA deductions contradicted jurisdictional HC precedent and failed. Treating both 80HHC and 80HHE on same profit was unsustainable, and disallowance of prior-period expenses was not a proper ground to reopen. The reassessment was set aside. Case-Laws Income Tax Thu, 23 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779893