Dismissing the petition the Court held that the assessee had not deducted tax at source. When the material was not considered at the time of original assessment the consideration thereof by the respondent could not be said to be a change of opinion or review of the earlier order. The order of reassessment was valid. (AY. 2014-15)
Bayer Vapi Pvt. Ltd. v. ACIT (2021) 438 ITR 495/(2022) 284 Taxman 267 (Guj.)(HC)
S. 147 : Reassessment-With in four years-Failure to deduct tax at source-Alternative remedy-Writ petition was dismissed. [S. 40(a)(ia), 43B, 148, Art. 226]