Allowing the petition, the Court held that the Assessing Officer while passing assessment order under section 143(3) had gone into assessee’s claim of depreciation on written down value of assets by making all necessary enquiries and he did not make any disallowance as regards said claim, in absence of any new tangible material, said assessment could not be reopened under section 147. (AY. 2010-11)
Solvay Specialities India (P.) Ltd. v. DCIT [2023] 149 taxmann.com 228 / 292 Taxman 537 /(2024) 338 CTR 121 (Bom)(HC)
S. 147: Reassessment –With in four years- Depreciation – Change of opinion – No new tangible material – Reassessment notice and order disposing the objection was quashed. [S. 132, 143(3), 148, Art. 226]