S. 147: Reassessment –Change of opinion-Since there was no material on record to indicate that there was a failure on part of the assessee to disclose fully and truly relevant material during original assessment proceedings, initiation of reassessment proceedings was without jurisdiction. [ S.80IA(4), 148 ]
Kotarki Constructions (P) Ltd. v. ACIT (2018)162 DTR 49 /( 2019) 306 CTR 223(Karn) (HC) .Editoria: Division bench affirmed ,Kotarki Constructions Pvt. Ltd; ACIT v. (2021)435 ITR 78/ 202 DTR 241/ 322 CTR 843 /281 Taxman 187 (Karn) (HC)
S. 147: Reassessment –Change of opinion-Since there was no material on record to indicate that there was a failure on part of the assessee to disclose fully and truly relevant material during original assessment proceedings, initiation of reassessment proceedings was without jurisdiction. [ S.80IA(4), 148 ]