Dy. CIT v. Sunflag Iron And Steel Co. Ltd. (2022) 96 ITR 9 (SN.) (Nag) (Trib)

S. 147 : Reassessment-Change of opinion-Industrial undertakings-Sale of surplus power-Reassessment is not valid. [S. 80IA(4)(iv)]

Tribunal held that  the power plant was established in a separate building and had its own separate and independent machinery, that the view of the Assessing Officer was glaringly contrary to the admitted facts available on record and within his knowledge and thus the reassessment proceedings were embarked upon on a mere “change of opinion”. Order of CIT(A) is affirmed.  (AY. 2010-11, 2011-12)