TMI Blog2018 (12) TMI 1594X X X X Extracts X X X X X X X X Extracts X X X X ..... of opinion and the correctness of this was tested by the Tribunal and the Tribunal noted that the required breakup details were furnished even at the time of original assessment and therefore, no new information available with the Assessing Officer nor any information was omitted by the assessee to be given to the Assessing Officer. Further, on the merits of the matter also, the Tribunal found ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unal Bench 'C', Chennai (hereinafter referred to as the Tribunal ) dated 18.08.2010, in ITA.No.857/Mds/2010 for the assessment year 2001.02. 2.The appeal has been admitted by order dated 23.02.2011, on the following substantial question of law:- Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in confirming the order of the Com ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd they are before us by way of this Tax Case Appeal. 5.The short question is whether factually the Commissioner (Appeals) as well as the Tribunal considered the validity of the reopening proceedings. At this juncture, it is worthwhile to following the finding recorded by the Commissioner (Appeals) vide its order dated 08.03.2010: 4.3..........The AO had sought clarification on this issue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... explanation. Therefore the Commissioner (Appeals) held that it is a clear case of change of opinion and the correctness of this was tested by the Tribunal and the Tribunal noted that the required breakup details were furnished even at the time of original assessment and therefore, no new information available with the Assessing Officer nor any information was omitted by the assessee to be given to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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