https://www.taxtmi.com/caselaws?id=782649 ITAT Mumbai quashed the reassessment initiated under s.147 r.w.s. 144B, holding the notice issued under s.148 to be invalid. The Tribunal found that the same income and the assessee's claim of deduction under s.80P had already been examined in the original assessment, with the addition deleted by CIT(A) and the legal issue now settled by SC. As no fresh, tangible material was brought on record, the reopening was held to be a mere change of opinion, which is impermissible in law. Consequently, the reassessment order was set aside. en-us Tue, 25 Nov 2025 00:00:00 +0530 Tue, 02 Dec 2025 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782649 ITAT Mumbai quashed the reassessment initiated under s.147 r.w.s. 144B, holding the notice issued under s.148 to be invalid. The Tribunal found that the same income and the assessee's claim of deduction under s.80P had already been examined in the original assessment, with the addition deleted by CIT(A) and the legal issue now settled by SC. As no fresh, tangible material was brought on record, the reopening was held to be a mere change of opinion, which is impermissible in law. Consequently, the reassessment order was set aside. Case-Laws Income Tax Tue, 25 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782649