Held that\u00a0 the\u00a0 assessee had received notice calling upon it to furnish details of brought forward losses and assessed losses, if any, along with proof and, assessee had provided all details as sought for.\u00a0 Therefore, reopening of assessment being merely by way of change of opinion relying on same set of primary facts which had been submitted by assessee during original assessment proceedings was to be quashed and set aside. As regards the expenditure\u00a0 the Assessee had replied to this notice by a communication addressed through assessee’s Chartered Accountants and in said document assessee had provided all details as sought for.\u00a0 In fact these figures were also mentioned in statement of profit and loss filed by assessee. Therefore, reopening of assessment being merely by way of change of opinion relying on same set of primary facts which had been submitted by assessee during original assessment proceedings was to be quashed and set aside.\u00a0 (AY.2013-14)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 147 : Reassessment-Carryforward and set off of brought forward losses-Business expenditure-Tax Audit Report-Provided all details in repose to notice-Provided break-up of head-wise expenses and these figures were also mentioned in statement of profit and loss filed by assessee, reopening of assessment being mere change of opinion was not justified. [S. 37(1), 72, 148, Art. 226] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-30332","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-7Te","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/30332","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=30332"}],"version-history":[{"count":2,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/30332\/revisions"}],"predecessor-version":[{"id":31888,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/30332\/revisions\/31888"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=30332"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=30332"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=30332"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}