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Income Tax - Highlights / Catch Notes

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Reopening of assessment u/s 147 - Change of opinion - The ...


Reopening Assessment u/s 147 Unjustified: AO's Change of Opinion and Lack of Due Diligence Not Grounds for Action.

August 24, 2023

Case Laws     Income Tax     HC

Reopening of assessment u/s 147 - Change of opinion - The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not discover even with due diligence, the petitioner cannot be blamed for that. If the AO did not examine the issue of allowability of the deduction during the course of regular assessment, the revenue has no jurisdiction to reopen the assessment. - HC

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