Dismissing the appeal of the revenue the Court held that , the Assessing Officer has objected to the audit objection , Apex court judgement was not available when the notice for reopening was issued, Change of opinion , therefore reassessment was held to be bad in law ( ITA No. 606 of 2015, dt. 24.02.2018)( AY. 2004 -05)
CIT v. Rajan N. Aswani ( 2018) 403 ITR 30 / 165 DTR 371 (Bom)(HC) , www.itatonline.org
S.147:Reassesment –With in four years-Audit objection- Reply of Assessing Officer to audit objection opposing the reassessment- , Apex court Judgement was not available- Reassessment was held to be bad in law . [ S. 80IB, 148 ]