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    Income Tax

    Reopening of assessment u/s 147 - claim of deduction u/s...

    Tax Reassessment Overruled: Court Finds No Income Escapement, Dismisses Change of Opinion by Assessing Officer.

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    Income TaxMarch 16, 2024Case LawsHC

    Reopening of assessment u/s 147 - claim of deduction u/s 36(1)(viia) - provision for Non-Performing Advances as per the RBI Regulations - The court observed that the petitioner had adequately addressed the AO's queries regarding the deduction claim during the original assessment. Additionally, the court noted that the petitioner had not claimed any deduction for rural advances, contradicting the basis for the alleged escapement of income. - The court deemed the reopening of the assessment as a clear case of change of opinion by the AO, which did not justify reassessment.

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