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TMI Blog2019 (7) TMI 1098X X X X Extracts X X X X X X X X Extracts X X X X ..... n the value of any asset is required to be added to the book profit for the purposes of Section 115-JB - following Jurisdiction High Court CIT(A) held that retrospective amendment in law does not give to any failure to disclose material facts as contemplated in the first proviso - HELD THAT:- The question of law as proposed by the Revenue is squarely covered by the two decisions which have been re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Income Tax Appellate Tribunal, Ahmedabd 'A' Bench, Ahmedabad in the the ITA No.3206/Ahd/2014 for the A.Y.2005-06 dated 14/11/2018 2. The Revenue has proposed the following question of law : Whether, the Appellate Tribunal has erred in law and on facts in upholding the decision of CIT(A) in quashing the reopening of the assessment under section 147 of the Act, 1961 without appreciating th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... acts as contemplated in the first proviso. 4. The question of law as proposed by the Revenue is squarely covered by the two decisions which have been referred to by the Tribunal in its impugned order. The principle of law as explained in the two decisions of this Court is that the retrospective amendment to any provision cannot be a ground for making re-assessment. Thus, the proposed question is s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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