1995 (12) TMI 69

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..... evenue for calling for a reference on the following two questions of law which read as under : " 1. Whether it was merely a change of opinion by the Income-tax Officer because he had considered this matter and had come to a definite conclusion, after obtaining a clarification from the assessee as contained in letter dated March 4, 1961, at the time of original assessment proceedings ? 2. Wheth .....

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..... ent on account of compensation on, the said land amounting to Rs. 1,79,000. The Income-tax Officer submitted his proposal to the Central Board of Direct Taxes for initiation of proceedings under section 147(a) of the Income-tax Act and for issuing notice under section 148 of the Act. The Income-tax Officer recorded the reasons and worked out the taxable capital gain at Rs. 1,31,448. The Central Bo .....

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..... e ground that it was a case of mere change of opinion by the Income tax Officer and, secondly, the sanction obtained from the Board was not in accordance with law. Therefore, the Revenue has moved this application for calling for a reference on the aforesaid questions of law. We have gone through the matter and we have perused the order of the Tribunal. The Tribunal on the basis of the facts, ha .....

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