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2018 (2) TMI 1646 - AT - Income TaxReopening of assessment - sale of scrap and miscellaneous income - mere change of opinion - change of opinion in a completed assessment u/s 143(3)- Held that:- Since in the instant case no new tangible material was available with the Assessing Officer and such re-assessment is based on the same materials as were available during the original proceedings since the issue of sale of scrap and miscellaneous income was considered by the AO in the body of the assessment order, therefore, the action of the Assessing Officer, in my opinion, is a mere change of opinion in a completed assessment u/s 143(3) and, therefore, find merit in the order of the ld. CIT(A) quashing such reassessment proceedings. The ld. DR also could not bring any material so as to take a contrary view than the view taken by the ld. CIT(A) nor could point out any in consistency in the order of ld. CIT(A). - Decided against revenue.
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