2011 (1) TMI 1370 - ITAT PUNE - Income Tax

Extract:
.......o;change of opinion” and, therefore, initiation of proceedings under section 147/148 of the Act dated 30.3.2006 cannot be said to be vitiated on this count. Therefore, on this aspect, assessee has to fail. 10. Resultantly, both the captioned appeals are dismissed. The decision was pronounced in the open Court on the 31st day of January, 2011.