Depreciation cannot be allowed forcefully if not claimed by Assessee

Brief of the case: Section 148 re-opening based on mere change of opinion not valid- ITAT Ahmedabad held in Gujarat Paguthan Energy Corporation P Ltd Vs ITO that AO could only reopen the assessment if he had reasons to believe that income had escaped assessment, he could not reopen the same only on the basis of mere change in opinion. He should have strong reasons to believe which should be filed. If the amount of debtors were shown as after deducting provision in the balance sheet then the same should be treated as a bad debt and should be allowed as an expense in calculation of MAT as  pro...