TMI Blog2022 (7) TMI 1472X X X X Extracts X X X X X X X X Extracts X X X X ..... been discussed, deliberated and verified by the AO at the time of original assessment proceedings. It seems that the AO had applied its mind and then passed the assessment order in favour of the petitioner. While passing the impugned order u/s 148A(d) AO has wrongly concluded that the assessee had not disclosed the sale of the property and long term capital gain in the ITR filed or was accepte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Act ) and the consequential notice dated 30th June, 2022 issued under Section 148 of the Act for the Assessment Year 2013-14. Learned counsel for the petitioner submits that the reassessment proceeding in the case of the petitioner is clearly a case of change of opinion . In support of his submission, he draws this Court s attention to the original assessment proceedings, which culminated i ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
