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Section 147

This query is : Resolved 
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(Querist)
20 March 2008 AO passed the order u/s 143(3)after considering transfer pricing report and also assessee disclose all the material fact for the assessment. Later on CIT revise the order on the ground that manner of application of arm's length price was not correct without any new fact. Can the AO reopened the past case on the basis of CIT order.
Wouldn't it be considered in change of opinion of AO and not be authenticated to reopen the case.
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Late CA Sampat Jain

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Late CA Sampat Jain (Expert)
20 March 2008 If you were aggrieved by the order of CIT u/s 263 setting aside the AO order or directing the AO to reopen the case , you should have filed appeal before ITAT against the same . Because with new judicial trends power of CIT to review stands curtailed .

If you have not file any appeal against order u/s 263 same has become final and is binding on AO
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