REASSESSMENT ::

Court :
HC

Brief :
Held by the Hon`ble Court that, the fact were before the assessing officer at the time of passing the original assessment, and later on different view was taken by his successor on the same facts it clearly amounted to a change of opinion. This could not form the basis for permitting the assessing officer or his successor to reopen the assessment of the assessee

Citation :
C.I.T. Vs. Eicher Ltd

Reassessment C.I.T. Vs. Eicher Ltd 05/22/2007 [2007] 294 ITR 300 (Delhi) Case Fact: Whether, reassessment is permissible on the basis of change of opinion? Decision: Held by the Hon`ble Court that, the fact were before the assessing officer at the time of passing the original assessment, and later on different view was taken by his successor on the same facts it clearly amounted to a change of opinion. This could not form the basis for permitting the assessing officer or his successor to reopen the assessment of the assessee
 

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