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2013 (12) TMI 1564 - AT - Income TaxReopening of assessment - Held that:- There was true disclosure of all material and primary facts at the time of original assessment and assessment was reopened in respect of the matter already covered by the disclosure made by the assessee during original assessment proceedings and initiation of reassessment proceedings on the same material would obviously amount to change of opinion. Consequently, we hold that the initiation of reassessment, in absence of any new tangible material was change of opinion which is not permissible as per statutory provisions of the Act. Accordingly, the act of the Assessing Officer in initiation of reassessment proceedings and notice issued u/s 148 of the Act is quashed.
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