Reopening- facets of claim

[rajul5234]

Guj. H.C. in S C A 29792/2007. Dt. 30/7/12. Quashed reopening within 4 years from year end  . However, vide para. 48 court observations by way of obiter on facets  of a claim appear  to be conflicting with the ratio of Kelvinator at 320 I T R 561(S.C.).

Views are invited from readers since I personally feel this para. 48 will create confusion and chaos on an issue already settled by Kelvinator's case by S.C.

R. K. Patel.