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TMI Blog2019 (10) TMI 1081X X X X Extracts X X X X X X X X Extracts X X X X ..... by the petitioner and had allowed the deduction claimed under section 80IA of the Act. As submitted that, therefore, the Assessing Officer seeks to reopen the assessment on a mere change of opinion, which is not permissible in law. It was submitted that even on merits, the reopening of assessment is bad. Having regard to the submissions advanced by the learned counsel for the petitioner, issue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted the attention of the court to the reasons recorded by the Assessing Officer for reopening the assessment, to submit that the same are based upon the material already on record. It was submitted that in this case, the impugned notice under section 148 of the Income Tax Act, 1961 (hereinafter referred to as the Act ) has been issued in relation to the assessment year 201213, which is clearly be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the issue, the Assessing Officer had accepted the explanation given by the petitioner and had allowed the deduction claimed under section 80IA of the Act. It was submitted that, therefore, the Assessing Officer seeks to reopen the assessment on a mere change of opinion, which is not permissible in law. It was submitted that even on merits, the reopening of assessment is bad. 3. Hav ..... X X X X Extracts X X X X X X X X Extracts X X X X
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