Held that in view of the findings recorded by the High Court on the questions raised and answers given, before the assessment order under section 143(3) of the Income-Tax Act, 1961 was passed, the court dismissed the petition without issuing notice in the special leave petition. The court observed that the assessee has no role to play and is not the author of the assessment order hence the manner and contents of the assessment order as framed are not determinative whether or not it is a case of change of opinion. SLP is dismissed. (AY.2013-14)
JCIT v. Cognizant Technology Solutions India Pvt. Ltd. (2023) 452 ITR 224 / 291 Taxman 526/(2024) 336 CTR 247 (SC) Editorial : Cognizant Technology Solutions India Pvt. Ltd v. ACIT(2021) 439 ITR 571 (Mad)(HC) is affirmed.
S. 147 : Reassessment-Change of opinion-Facts available in the original assessment proceedings-Reassessment is not valid. [S. 143(3), 148, Art. 136]