PCIT v. West Bengal Essential Commodities Supply Corporation Ltd. (2022) 289 Taxman 113 (Cal.)(HC)

S. 147 : Reassessment-Business expenditure-Increase in freight charges vis-a-vis purchases-Change of opinion-No new material-Reassessment is bad in law. [S. 37(1), 148]

Dismissing the appeal of the Revenue the Court held that the  Assessing Officer did not refer to any new material that came into his possession based on which it could be opined that income chargeable to tax had escaped assessment, reassessment proceeding was merely based on change of opinion and, thus, reassessment was unjustified. (AY. 2005-06)