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2013 (6) TMI 518 - ITAT DELHIRe opening of assessment - addition of treatment under the income of other source by the AD as against income from house property as offer by assessee - Held that:- AO reopened the assessment and issued notice u/s 148 on the same material which was placed before him during the original assessment u/s 143(3). AO raised specific queries pertaining to the amounts received from PVR Ltd. and its treatment by assessee as income from house property. The AO concluded the original assessment by considering the same as income form house property. Subsequently, on the same material the AO recorded satisfaction u/s 147 and issued notice u/s 148 which is clearly a change of opinion and hence, CIT(A) rightly held that issuance of notice u/s 148 is bad in law. Against revenue.
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