TMI Blog1995 (4) TMI 280X X X X Extracts X X X X X X X X Extracts X X X X ..... les Tax Act, 1957 for the assessment years 1988-89 and 1989-90. The basis for initiation of proceedings under section 12-A is the inspection report sent to the assessing authority on May 11, 1992. This report was not available on the date when the order was made for the assessment year 1988-89 because the order of assessment was made on June 10, 1989. In those circumstances on the fresh informatio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he matter it would merely amount to change of opinion and not a proceeding initiated on the basis of the material made available for the first time which was not originally available to the authority. In that view of the matter, the proceedings initiated under annexure E shall stand quashed.
3.. The petitions shall stand disposed of accordingly.
Petitions disposed of accordingly. X X X X Extracts X X X X X X X X Extracts X X X X
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