Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (6) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (6) TMI 1269 - AT - Income TaxReopening of assessment - bad debts written off disallowed - HELD THAT:- The details of bad debts written off were called for by Ld. AO during the course of original assessment proceedings. The assessee had supplied the requisite details. After considering the assessee’s reply, AO disallowed bad debts to the extent of Rs. 204.26 Lacs and chose not to make any further addition on this account. There is no further discussion whatsoever in the assessment order, in this regard. When the complete details were asked for and the same were duly furnished by the assessee and Ld. AO chose to disallow a part of the same, it could rightly be concluded that the issue was duly considered by AO with due application of mind and a conscious decision was taken in the matter. To reopen the already concluded assessment on the same very issue would be nothing but review of the order and on mere change of opinion which is impermissible as per the decision in the case of CIT vs. Kelvinator of India Ltd. [2010 (1) TMI 11 - SUPREME COURT]. Therefore, impugned order could not be faulted with and we concur with the same.
|