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2014 (4) TMI 817 - AT - Income TaxValidity of reassessment order u/s 147 of the Act - Treatment of technology expenses – Mere change of opinion - Held that:- Neither the AO nor the DR was able to pinpoint, as to what material was gathered or came to light, which was resulted or indicated that there was an escapement of income, to attract reassessment proceedings - The issue was examined by the AO thread bear, is apparent from the fact that the disallowance made by the AO on technological expenses traveled up to the ITAT, itself proves the issue against the revenue authorities that they were proceeding on the aspect with a different reasoning - the law does not allow proceedings based on change of opinion from one incumbent to the other – Relying upon Kelvinator of India vs CIT [2002 (4) TMI 37 - DELHI High Court] - the AO has traveled beyond the statutory accord – Decided in favour of Assessee.
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