Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2019 (11) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (11) TMI 696 - ITAT PUNEReopening of assessment u/s 147 - absence of cumulative satisfaction of reason to believe -HELD THAT:- In the present case, the notice of reopening the assessment u/s 148 of the Act is on account of change of opinion by the AO, which is not permissible as per law. We are therefore of the view that the impugned notices cannot be sustained and the same deserves to be quashed and set aside. We therefore quash the impugned reassessment proceedings for A.Y. 2006- 2007 are thus set aside the same. Since we have hereinabove set aside the assessment framed u/s 143(3) r.w.s 147 of the Act and held it to be void therefore the issue on merits have been rendered academic and requires no adjudication. Thus, the grounds of Assessee are allowed.
|