https://www.taxtmi.com/caselaws?id=464276 ITAT MUMBAI held that reopening assessment u/s 147 was not justified as the issue regarding deductions u/s 36(1)(vii) and 36(1)(viia)(c) had been fully considered in the original assessment u/s 143(3). The AO had access to and applied relevant information, computed the deduction and incorporated adjustments in the assessment order; there was no concealment or escapement by the assessee. Reassessment amounted to an impermissible change of opinion. The revenue's grounds for reopening were dismissed. en-us Mon, 26 Feb 2024 00:00:00 +0530 Wed, 15 Oct 2025 20:49:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464276 ITAT MUMBAI held that reopening assessment u/s 147 was not justified as the issue regarding deductions u/s 36(1)(vii) and 36(1)(viia)(c) had been fully considered in the original assessment u/s 143(3). The AO had access to and applied relevant information, computed the deduction and incorporated adjustments in the assessment order; there was no concealment or escapement by the assessee. Reassessment amounted to an impermissible change of opinion. The revenue's grounds for reopening were dismissed. Case-Laws Income Tax Mon, 26 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464276