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2015 (6) TMI 847 - AT - Income TaxReopening of the assessment u/s. 147 - addition being interest income accrued on fixed deposits and addition being expenditure on capital spares consumed being capital in nature - Held that:- AO has no fresh material to form his opinion regarding escapement of assessment and he has also ot found any tangible material to record the reasons for reopening of the assessment of the assessee. It is merely a change of opinion which is not permissible under the law as well as according to the various decisions rendered by the Hon’ble Supreme Court of India in the case of CIT vs. Kelvinator of India Limited [2010 (1) TMI 11 - SUPREME COURT OF INDIA ] and in the case of CIT vs. Foramer France (2003 (1) TMI 101 - SUPREME Court) and Sita World Travels (India) Ltd. vs. CIT (2004 (5) TMI 23 - DELHI High Court ) - Decided in favour of assessee.
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