Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (1) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (1) TMI 19 - AT - Income TaxReopening of assessment u/s 147 read with section 148 of the Act - disallowance of the claim of deduction under section 10B of the Act - manufacturing activity or not? - Held that: - the AO has formed an opinion during the course of original assessment proceedings and this reopening is merely on change of opinion, which is not permissible under section 147 of the Act - From the very reasons recorded by AO for reopening of assessment, it is clear that the AO was of the view that the AO was wrongly allowed on the ground that process of making power from whole Spices do not constitute manufacture within the meaning of section 10B of the Act - this is merely change of opinion and nothing else - appeal dismissed.
|