Allowing the petition the Court held that ; successor Officer seeking to reopen the assessment on same grounds examined by the predessor officer was held to be not valid .Reassessment on Grounds other than those stated in reasons recorded was held to be impermissible. Disposal of objection raised by the assesee was held to be not mere formality , hence reassessment was held to be not valid .( AY.2010-11)
Vijay Harishchandra Patel. v. ITO (2018) 400 ITR 167/ 167 DTR 475 (Guj) (HC)
S. 147: Reassessment — With in four years -Change of opinion- Reassessment was held to be not valid [ S. 148 ]
Vijay Harishchandra Patel. v. ITO (2018) 400 ITR 167