Dismissing the appeals of the revenue the Court held that the reopening, based upon a change of opinion or a review of the decision taken by the Assessing Officer was impermissible. The Tribunal was right in setting aside the order of reassessment.( AY.2009-10)
PCIT v. Shree Laxmi Jewellery Pvt. Ltd. (2020) 428 ITR 379 (Mad)(HC)
S. 147 : Reassessment –With in four years- Change of opinion -Speculative transaction — Business of manufacturing and trading of bullion and jewellery- Review of decision is impermissible – Business loss- Held to be not valid [ S.43(5), 148 ]