Dismissing the petition the Court held that the objections raised regarding the reasons were dealt with by the respondents. The other issue regarding change of opinion is also considered. AO has spelt out certain reasons, which provided a cause for reopening of assessment and such reasons are sufficient enough and if the assessee is not convinced, it is left open to him to defend the case during reassessment proceedings. (AY. 2011-12)
Sutherland Global Services (P) Ltd. v. Dy. CIT (2021) 208 DTR 265 (Mad.)(HC)
S. 147 : Reassessment-With in four years-Audit objection-Survey-Reassessment notice was held to be valid. [S. 133A, 148, Art. 226]