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2011 (3) TMI 1038 - AT - Income TaxReopening of assessment - Capital Investment Subsidy receivable from Punjab Small Industries and Export Corpn. Ltd. - Capital or revenue receipt - Held that:- A perusal of the reasons recorded by the AO for initiating reassessment proceedings clearly shows that on the very same material which was available while completing the assessment under section 143(3) of the Act he had on a mere change of opinion issued notice for reassessment - Merely because while completing original assessment the AO has not discussed the issue does not mean that he has not expressed any opinion - the reassessment proceedings under section 147 has not been validly initiated because the same were initiated merely on a change of opinion without any fresh material coming into the possession of the AO - Decided in the favour of assessee
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