TMI Blog2019 (11) TMI 215X X X X Extracts X X X X X X X X Extracts X X X X ..... n compliance of his directives as per their intimation to the petitioner. As submitted that therefore, in connection with the transaction in question, the Assessing Officer had summoned the party and had duly verified the same and thereafter, had passed the assessment order. As submitted that therefore, it is evident that the Assessing Officer seeks to reopen the assessment on a mere change of opi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sued under section 148 of the Act for Assessment Year 2012-13. - R/SPECIAL CIVIL APPLICATION NO. 18915 of 2019 - - - Dated:- 22-10-2019 - JUSTICE HARSHA DEVANI AND JUSTICE SANGEETA K. VISHEN, JJ. For The Petitioner (s) : MS VAIBHAVI K PARIKH (3238) ORAL ORDER ( PER : HONOURABLE MS.JUSTICE HARSHA DEVANI) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t after such statement came to be recorded, scrutiny assessment came to be carried out and hence, the statement recorded in 2013 would not constitute fresh material in the eye of law so as to enable the Assessing Officer to reopen the assessment under section 147 of the Act. 2. It was submitted that even on merits, the issue came to be examined during the course of scrutiny assessm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mitted that therefore, in connection with the transaction in question, the Assessing Officer had summoned the party and had duly verified the same and thereafter, had passed the assessment order. It was submitted that therefore, it is evident that the Assessing Officer seeks to reopen the assessment on a mere change of opinion. 3. As regards the second ground on which the assessmen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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