2017 (8) TMI 245

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..... sessment and the decision of the Assessing Officer was supported by various judicial pronouncements. The Tribunal relied upon the judgment of this Court in case of Rallis India (2010 (3) TMI 164 - BOMBAY HIGH COURT) to state that retrospective amendment could not have been the sole ground for reopening of the assessment. Clause (i) of the Explanation I to Section 115JB of the Act was brought into .....

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..... notice is issued. The reopening was within four years. According to the learned Counsel, the decision relied upon by the Tribunal in Rallis India Ltd. 323 ITR 54 (Bom) is distinguishable on the facts that the Assessing Officer had neither called for the details of the provision for diminution in the value of assets nor raised any query in regard to the addition of the same to the net profit in the .....

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