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2009 (12) TMI 543 - DELHI HIGH COURT
Reassessment proceedings - section 147/147 - reasons for reopening an assessment - Held that: - The only reason which has been given seeking reopening of the assessment for the years 1997-98 and 1998-99 is that suppression of sales has taken place on account of the fact that when average price of the closing stock is mul-tiplied with the quantity of the sales in the year then the value of the sales would be at a higher figure than that as declared by the assessee. - he reasons given for seeking reopening of the assessment contains the expression "perusal of the case record reveals" clearly showing that it is on the basis of the same assessment record as was filed by the assessee, during the relevant assessment years - merely change in an option can not be the basis for reassessment - notice u/s 148 quashed.