Allowing the petition the court quashed the notice issued under section 148 of the Income-tax Act, 1961 and the order rejecting the objections of the assessee to the reopening of the assessment under section 147 for the assessment year 2012-13 applying their decision in the assessee’s own case for another assessment year. Followed, Oracle Financial Services Software Ltd. v. ACIT (No 1) (2023) 452 ITR 272 (Bom)(HC) (AY.2012-13)
Oracle Financial Services Software Ltd. v. ACIT (No. 2) (2023) 452 ITR 279 (Bom.)(HC)
S. 147 : Reassessment-After the expiry of four years-Change of opinion-Reassessment notice and order disposing the objection was quashed. [S. 148, Art. 226]