CIT v. Trichy Steel Rolling Mills Ltd. (2022) 286 Taxman 595 (Mad.)(HC)

S. 147 : Reassessment-After the expiry of four years-Bad debts-Change of opinion-No tangible material-Reassessment was quashed. [S. 36(1)(vii), 148]

Dismissing the appeal of the Revenue the Court held that reassessment proceedings had been initiated without any tangible material evidence, unearthed subsequently, which assessee did not produce at time of original assessment under section 143(3) of the Act.  Reassessment proceedings were based on change of opinion hence the Tribunal was right in allowing appeal filed by assessee. (AY. 1998-99)