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The High Court of Bombay ruled that the Income-tax Officer's reopening of the assessee's assessment for the year 1976-77 under section 147(b) was invalid as there was no fresh information to justify it. The Tribunal's decision to cancel the assessment was upheld. The court found that the reason for reopening was a mere change of opinion, not fresh information as required by law. The rule was discharged with no costs awarded.
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