2023 (1) TMI 961 - AT - Income Tax
Reopening of assessment u/s 147 - denying the claim of deduction u/s. 80IA(4) - HELD THAT:- It is very clear from the original assessment proceedings, AO vide his notice u/s. 142(1) dated 19.01.2011 requested the assessee to submit copy of the stock statement furnished to the bank to avail cash credit facility by the assessee. The assessee submitted the details to the AO vide its reply enclosed the copies of the stock which is clearly mentioning 52.66 lakhs.
AO has examined the issue of stock, during the original assessment proceedings and do not find any discrepancy in the stock submitted by the assessee and completed the assessment order u/s. 143(3) of the Act. It is settled principle of law, no assessment can be reopened on the basis of change of opinion - Decided against revenue.