Dismissing the appeal of the revenue the Court held that there was no failure to disclose any material facts and the AO has correctly assessed the lease rental as business income , reopening of assessment is due to change of opinion hence bad in law . (AY. 2003-04, 2005-06)
CIT v. Tidel Park Ltd (2020) 317 CTR 440 / 195 DTR 191 (Mad) (HC)
S. 147 : Reassessment – Developing, operating and maintaining information technology parks – Lease rental – Change of opinion – Reassessment is held to be bad in law [ S.80IA(iii), 148]