No re-opening of assessment on mere change of opinion without nexus with original materials

Facets Gems Polishing Works Private Limited Vs DCIT (Gujarat High Court)

Conclusion: Re-opening of assessment on mere change of opinion without there being any live link or nexus with the material relied upon as during the regular assessment proceedings was not valid as AO had examined the claim under section 80IA(4)(iv) in detail by raising various queries which were duly answered by assessee.

Held: Assessee was engaged in diamond manufacturing, trading, and windmill power generation, had claimed deductions under sections 35DD and 80IA(4)(

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