Allowing the petition the Court held that the Assessing Officer has allowed the claim of the assessee after considering the material produced in the original assessment proceedings. Reassessment proceedings is initiated due to change of opinion, there was no suppression of facts. The notice and order disposing the objection is quashed. (AY. 2016-17)
Shrikant Vasudev Naik v. ACIT ( 2023) 333 CTR 684 ( Bom)( HC) Indirabai Shrikant Naik v. ACIT ( 2023) 333 CTR 684 ( Bom)( HC)
S. 147 : Reassessment –With in four years-Capital gains-Change of opinion-No suppression of material facts-Reassessment notice and order disposing the objection is quashed. [S. 45, 143(3), 148, Art. 226]