Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2019 (6) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (6) TMI 615 - GUJARAT HIGH COURTReopening of assessment u/s 147 - original order u/s 143(3) - change of opinion - disallowance made of loss on sale of stores treating them to be revenue in nature - HELD THAT:- The finding of fact recorded by the Appellate Tribunal is that no new material has surfaced on the basis of which the assessment proceedings could be reopened. It appears that the reopening was clearly on account of change of opinion by the AO and this is something which is not permissible under the scheme of the Act. This principle has been well explained by this court in the above referred decision in the case of Gujarat Power Corporation [2012 (9) TMI 69 - GUJARAT HIGH COURT] . - appeal of revenue is dismissed
|