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2018 (5) TMI 1434 - HC - Income TaxReopening of assessment u/s 147 - Computation of book profits u/s 115JB - MAT - notices have been issued beyond the period of four years - addition made by AO on account of subsidy grant being capital in nature - Held that:- an assessment previously framed cannot be reopened on a mere change of opinion - it is stated that power to reopening cannot be equated with review - if AO during scrutiny assessment notices a claim of exemptions made by the assessee having some prima facie doubt and asking the assessee to satisfy him with respect to such a claim and thereafter, does not make any addition in the final order of assessment, he can be stated to have formed an opinion whether or not in the final order he gives his reasons for not making the addition - hence notices quashed.
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