TMI Blog2010 (10) TMI 803X X X X Extracts X X X X X X X X Extracts X X X X ..... ated 7.1.2010 under Section 148 of the Income Tax Act, 1961 (for short, "the Act") and order dated 17.12.2010, rejecting objection of the petitioner to the notice for reassessment. 2. The petitioner let out its plant and machinery and treated the income received to be 'business income'. It claimed deductions on the account of business expenses. The return for the assessment year 2007-08 wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (2002) 256 ITR 774 (PandH). 3. We have heard learned counsel for the petitioner. 4. The submission on behalf of the petitioner cannot be accepted. It is not disputed that for the assessment year in question no scrutiny assessment was made and merely return was processed. In such a case, there was no question of mere change of opinion. The reasons for assessment show that according ..... X X X X Extracts X X X X X X X X Extracts X X X X
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