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TMI Blog2019 (1) TMI 762X X X X Extracts X X X X X X X X Extracts X X X X ..... tion 133A was conducted and that during such scrutiny assessment, the statement recorded from the Managing Director of the assessee was not taken into consideration by the Assessing Officer. Therefore, there was no opinion formed by the Assessing Officer on the said issue under the head of income. Further, the assessee themselves accepted that the income was earned, but not disclosed in the return ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r the Respondent : Mr.T.R.Senthilkumar, SSC COMMON JUDGMENT T.S.SIVAGNANAM, J. These appeals by the assessee under Section 260A of the Income Tax Act, 1961 (hereinafter called the Act) are directed against the common order passed by the Income Tax Appellate Tribunal (for short, the Tribunal), Chennai in ITA.Nos.1284 and 1285/Mds/2017 dated 27.9.2017 for the assessment years 2003-04 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alid when reopening on the same set of materials will amount to change of opinion? and iv. Whether interest under Section 234B can be charged upto the date of reassessment or only upto the date of regular assessment ? 3. We have heard Mrs.G.Vardini Karthik, learned counsel for the appellant/assessee and Mr.T.R.Senthilkumar, learned Senior Standing Counsel accepting notice for the Revenue ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e s case is that the reopening is a clear case of change of opinion and that there is no allegation that the assessee failed to fully and truly disclose all the details. 7. In our considered view, the CIT(A) as well as the Tribunal rightly appreciated the factual position and noted that the scrutiny assessment was taken up since the survey under Section 133A of the Act was conducted and that du ..... X X X X Extracts X X X X X X X X Extracts X X X X
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