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2014 (2) TMI 362 - AT - Income TaxValidity of assessment u/s 143(3) r.w.s. 147 - Held that:- Both the issues were properly examined by the A.O. during the course of original assessment proceeding u/s 143(3) of the Act - The same were allowed by the A.O. after applying his mind - There was no tangible material in possession of A.O. to be treated as reasons for escapement of income - The assessment completed originally u/s 143(3) of the Act was reopened by the A.O. on the basis of same set of facts and same material which was available at the time of completing the assessment originally u/s 143(3) of the Act and the reopening was clearly based on a mere change of opinion which is not permissible - Decided against Revenue.
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