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2014 (9) TMI 1080 - CALCUTTA HIGH COURTReopening of assessment - Held that:- The grounds on which the Income Tax Department were purporting to reopen the assessment are mentioned in their letter dated 27th November, 2013, which is annexure P-6 at page 51 of the petition. All the issues were before the assessing officer and the appellate authorities, in my opinion. Nothing is mentioned in the said letter of the department which can be said to be new and could not be known to them in spite of due diligence at the time of making the assessment. There is no scope of reopening an assessment on a mere change of opinion.On identical facts, the Hon’ble High Court of Gujarat pronounced a similar dictum in Transwind Infrastructure [P] Ltd. vs. Income-tax Officer, Ward-8(1) [2013 (5) TMI 52 - GUJARAT HIGH COURT ] - Decided in favour of assessee
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