Allowing the petition the Court held that the revenue could not satisfy the Court about new material of documents came in to possession of the Assessing Officer after the assessment order which was passed u/s 143(3) of the Act. Order rejecting the application was set aside and the matter was remanded to consider regarding change of opinion. (AY. 2013-14)
Magma Hdi General Insurance Co. Ltd. v. ITO (2021) 439 ITR 329 / 206 DTR 57 / 322 CTR 750 (Cal.)(HC)
S. 147 : Reassessment-With in four years-No new material-Matter remanded to consider the issue on change of opinion. [S. 148, Art. 226]