The Kerala High Court in (2021) 18ITR-OL 459 stopped the AO from changing the method of computing deduction u/s 36(1) (viia). In this case the AO initiated rectification alleging excess allowance of deduction in original scrutiny assessment while referring to eligibility criteria.
The High Court held that a mistake which is appreciated upon due deliberation and consideration of the very same circumstances for recording change of opinion/conclusion does not come within the ambit of section 154.
Apparently therefore in such a situation there may be no reopening possible u/s 147/148 as well if we go by this understanding.
https://dailytaxreporter.com/2021/11/15/finality-cannot-be-disturbed-in-carrying-out-any-rectification-u-s154/
