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| The Tax Publishers2020 TaxPub(DT) 1024 (Bom-HC) : (2020) 269 TAXMAN 0278 INCOME TAX ACT, 1961
Section 147
Since very issue on which AO had made reasons to believe that income chargeable to tax had escaped assessment were subject matter of regular assessment proceedings under section 143(3), it was case of change of opinion by AO.
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Reassessment - Validity - Issue already dealt by AO during original scrutiny assessment -
Assessment in case of assessee was completed under section 143(3). AO issued notice under section 148 after 4 years from end of relevant assessment year on ground that income chargeable to tax had escaped assessment doubting genuineness of transaction of issue of shares by assessee-company to its existing shareholders. Held: Since very issue on which AO had made reasons to believe that income chargeable to tax had escaped assessment were subject matter of regular assessment proceedings under section 143(3), it was case of change of opinion by AO. However, revenue's counsel sought time to take instructions and matter was adjourned. As an ad interim relief reassessment proceedings were stayed.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
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