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TMI Blog2017 (8) TMI 1435X X X X Extracts X X X X X X X X Extracts X X X X ..... ch payments on the ground that the deduction of tax at source was not carried out, it was open for him to do so after hearing the assessee. We do not see any reason to interfere in the Tribunal’s order declaring the process of reopening of assessment as illegal. In that view of the matter, we have not examined the correctness of the discussion of the Tribunal in the impugned order pertaining t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Income Tax Appellate Tribunal dated 29.07.2016. The following questions have been raised for our consideration in Tax Appeal No. 563 of 2017. [A] Whether the Appellate Tribunal erred in law and facts in quashing the re-assessment order passed u/s 143(3) read with section 147 of the Income Tax Act, 1961 holding that the same was on account of mere change of opinion? [B] Whether th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the validity of reopening of assessment, the Tribunal has reversed the same. It is in this context the first question is suggested by the Revenue. 3. Having perused the materials on record, we do not see any failure on the part of the assessee to disclose truly and fully all material facts. The payments were part of the return filed by the assessee. If the Assessing Officer desired to disallow ..... X X X X Extracts X X X X X X X X Extracts X X X X
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