9911796707
TMI Blog2014 (9) TMI 1080X X X X Extracts X X X X X X X X Extracts X X X X ..... sessing officer and the appellate authorities, in my opinion. Nothing is mentioned in the said letter of the department which can be said to be new and could not be known to them in spite of due diligence at the time of making the assessment. There is no scope of reopening an assessment on a mere change of opinion.On identical facts, the Hon’ble High Court of Gujarat pronounced a similar dictum in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ioner showed me a letter of the writ petitioner dated 27th November, 2013. It appears that there was scrutiny assessment of the writ petitioner s return under section 143[3] of the Income Tax Act for the same assessment poeriod Against the assessment order an appeal was preferred before the Commissioner of Income Tax [Appeals] by the writ petitioner which went in their favour. An appeal from this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... fficer, Ward-8(1); [2013] 33 taxmann.com 404. For all those reasons, on the above prima facie case, I pass an interim order in terms of prayer [l] of the petition till disposal of this writ application. This writ application is formally admitted. Let affidavit in opposition be filed by 3rd November, 2014. List this application on 17th November, 2014. Affidavit in reply, if any, may be fil ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
