Reassessment Upheld Due to No Prior Examination of Section 80HHC Deduction Claim

Jasmine Towels Private Ltd. Vs ACIT (Madras High Court) The appeal concerned the validity of reassessment proceedings initiated under Section 147 of the Income-tax Act, 1961 for Assessment Year 2004–05. The assessee challenged concurrent orders of the Assessing Officer, the first appellate authority, and the Tribunal, all of which upheld the assumption of jurisdiction for reopening the assessment. The substantial question of law was whether the reassessment was invalid as being based on a mere change of opinion. The assessee had originally filed a return claiming deduction under Section 80HH...