2023 (7) TMI 416 - SCH - Income Tax

Reopening of assessment u/s 147 - deduction u/s 80IB(10) denied - As per HC as during the course of scrutiny assessment AO had examined the claim for deduction u/s 80IB(10) in detail, therefore, merely because he did not examine such claim from the angle of clauses (e) and (f) thereof, would not be a valid ground for reopening the assessment as it would amount to a mere change of opinion . HELDTHAT - In terms of Circular No. 17/2019 dated 08.08.2019 issued by Government of India, Ministry of Finance, Department of Revenue, Central Board Direct Taxes, Judicial Section, since the amount of tax involved is low, we are not inclined to interfere with the impugned order. SLP dismissed.

Summary

The Supreme Court dismissed the special leave petition as the tax amount involved was low, following Circular No. 17/2019 issued by the Government of India, Ministry of Finance.