2017 (8) TMI 727

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..... under Section 143(2) of the Act was issued. The explanation was given by the Assessee. In the explanation, the Assessee explained about the claim for setof of loss incurred on selling of housing loan portfolio. The Assessing Officer accepted the explanation given by the Assessee and allowed set-of of loss arising on sell of housing loan portfolio. Merely because the another Assessing Officer has a .....

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..... d A. M. Badar, JJ. Mr. Suresh Kumar for the Appellant ORDER Per Court : 1] The appeal pertains to Assessment Year 2005-06. 2] Mr.Suresh Kumar, the learned counsel for the Appellant submits that the Tribunal was not justified in annulling the Assessment, reopened under Section 148 of the Income Tax Act, 1961 (for short the Act ), on the ground of change of opinion by the Assess .....

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..... d on selling of housing loan portfolio. The Assessing Officer accepted the explanation given by the Assessee and allowed setof of loss arising on sell of housing loan portfolio. Merely because the another Assessing Officer has a different opinion cannot be a ground to reopen assessment and so also on the reason of audit object remedial action by initiating reopening proceeding cannot be resorted t .....

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