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TMI Blog2012 (6) TMI 808X X X X Extracts X X X X X X X X Extracts X X X X ..... ribunal has recorded that a mere change of opinion between two officers in reopening of the assessment and it is not legally permissible. We, therefore, do not find any infirmity and illegality in the impugned judgment and order dated 12th January, 2012 passed by the learned Tribunal. - ITAT No.108 of 2012 & GA No.1510 of 2012 - - - Dated:- 15-6-2012 - KALYAN JYOTI SENGUPTA AND ASIM KUMAR MOND ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ious judgments and decisions on this point which squarely fits in the facts of the present case? c. Whether on the facts and in the circumstances of the case as well as in law the order passed by the I.T.A.T is perverse as proper facts were ignored? d. Whether on the facts and in the circumstances of the case as well as in law the Tribunal was justified in quashing the reassessment ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent years claimed and allowed as expenditure, hence the amount in question shall be deemed to be profits and gains of the business of the assessee. Accordingly the addition made by the AO is confirmed. The learned Tribunal after examining the records and having gone through the judgment and order available before it, came to the conclusion that there was no new material or information which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat a mere change of opinion between two officers in reopening of the assessment and it is not legally permissible. We, therefore, do not find any infirmity and illegality in the impugned judgment and order dated 12th January, 2012 passed by the learned Tribunal. Accordingly, we do not admit the appeal and the same is dismissed. In view of the dismissal of the appeal itself the connected app ..... X X X X Extracts X X X X X X X X Extracts X X X X
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