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TMI Blog2021 (12) TMI 1139X X X X Extracts X X X X X X X X Extracts X X X X ..... itish Chatterjee for Respondents - Revenue. ORDER P. C. :- 1. Petitioner is impugning a notice dated 30/03/2019 issued under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for AY 2012-13 where Respondents have alleged that they have reasons to believe that Petitioner's income chargeable to tax for AY 2012-13 has escaped assessment within the meaning of Section 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on 25/11/2019 and further time was granted on 30/01/2020. Mr. Walve submitted that there is no change of opinion and the reasons indicate that there has been non-disclosure of material facts. Mr. Walve also relied on Explanation (1) to Section 147. 5. We have considered the reasons and in our opinion, Petitioner is correct in its submissions that it is nothing but change of opinion. It is pertin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0-13 being expenditure not related to the period under consideration". This is certainly change of opinion. 6. Paragraph 3.2 also relates to payment of rent for 5 outlets and repairs and renovation for all the outlets and that paragraph ends as, "..... The Assessing Officer has not examined these issues .....". Therefore, it is nothing but change of opinion based on which assessment cannot be re- ..... X X X X Extracts X X X X X X X X Extracts X X X X
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