Held that assessee’s brother’s case on similar facts and circumstances of the issue, the court set aside the notice issued under section 148 to reopen the assessment under section 147 and the order rejecting the assessee’s objections. Accordingly, the petition was allowed. Followed Asraf Alibhai Nathani v. ACIT (2023) 452 ITR 292 (Bom)(HC)
Arshad Alibhai Nathani v. ACIT (2023) 452 ITR 301 (Bom.)(HC) Editorial : SLP of Revenue dismissed, CIT v. Arshad Alibhai Nathani(2023) 452 ITR 415 (St)(SC)
S. 147 : Reassessment-Change of opinion-Notice and order-disposing the objection was quashed. [S. 148, Art. 226]