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2019 (8) TMI 738 - HC - Income TaxReopening of assessment u/s 147 - change of opinion - HELD THAT:- The Appellate Tribunal, as a last fact finding authority, has taken the view that the reopening is nothing, but change of opinion and there was no failure on the part of the assessee in disclosing all the necessary information for the purpose of making assessment. We take notice of the fact that the Tribunal has relied upon a decision of this Court in the case of Sadbhav Engineering Ltd vs. DCIT [2010 (7) TMI 521 - GUJARAT HIGH COURT] We are convinced that no error, not to speak of any error of law could be said to have been committed in passing the impugned order. - Decided against revenue.
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