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2018 (9) TMI 1793 - ITAT CHENNAIValidity of revisions - change of opinion - Section 25(2) of Wealth Tax Act - Held that:- Admittedly the return in Form-BA is a statutory form and in the said Form, provision has been provided for claiming the set off of the debts owed in relation to asset ‘cash on hand’. When such set off is permissible while computing the value of the specified asset u/s.2(ea)(vi) of the Act, interpretation to section 2(m) is only a change of opinion. In any case, the ld. Assessing Officer, when completing the assessment u/s.16(3) of the Act, has also examined the issue of assessee’s claim in respect of set off of the debts owed in relation to asset ‘cash on hand’. Thus, the order passed u/s 25(2) of the Act by the Principal Commissioner of Wealth Tax is clearly on a change of opinion, which is not permissible for the purpose of revision. The order passed u/s.25(2) of the Act by the Principal Commissioner of Wealth Tax, Central-2, Chennai is set aside as it is done on the basis of change of opinion, which is not permissible u/s.25(2) of the Act - appeal allowed.
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