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2018 (2) TMI 355

Head Note:
Reopening of assessment - validity of reasons to believe - computation of income as NIL - Held that:- The assessment order clearly reveals that a detailed questionnaire had been issued to the assessee along with the notice under section 142(1). The submissions of details and explanation furnished by the petitioner clearly show that it has explained that the firm was converted into a company with all assets and liabilities and that the profit earned by the firm was disclosed in the profit and loss account of the company. The Assessing Officer, upon being convinced by the explanation given by the petitioner, has accepted the return of income as filed by the petitioner during the course of scrutiny assessment. Thus, it is evident that the Assessing Officer has applied his mind to the issue in question and has accepted the same.

Assessing Officer in the assessment order, has recorded that after verification and discussion and from the data made available, the total income of the assessee is computed as nil. Evidently therefore, the Assessing Officer has applied his mind to the fact that the assessee had filed nil return of income and had accepted the same. Under the circumstances, the court is of the view that the reasons recorded for reopening the assessment reflect a mere change of opinion, inasmuch as, the Assessing Officer has already applied his mind to this aspect.

Reopening of assessment being based upon a mere change of opinion. - Decided in favour of assessee

 


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