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| The Tax Publishers2020 TaxPub(DT) 3997 (SC) : (2020) 274 TAXMAN 0230 INCOME TAX ACT, 1961
Section 261 Section 147 Section 148
Where the department preferred SLP to appeal against the judgment of Gujarat Hgh Court in The Pr. CIT 1 v. Atul Limited [R/Tax Appeal No. 7 of 2019, dt. 10-6-2019] : 2019 TaxPub(DT) 4320 (Guj-HC), whereby the High Court held that the finding recorded by tribunal was that no new material had surfaced on the basis of which the assessment proceedings could be reopened that, it appeared that the reopening was clearly on account of change of opinion by the AO and this is not permissible under the scheme of the Act, further this principle was well explained by this Court in the case of Gujarat Power Corporation 2013 TaxPub(DT) 409 (Guj-HC), the Supreme Court not seeing any reason to interfere in the matter, dismissed the SLP leaving all the questions of law open.
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Appeal (Supreme Court) - Special leave petition - Reassessment - Validity--No new fact came to notice of AO
Department preferred SLP to appeal against the judgment of Gujarat Hgh Court in The Pr. CIT 1 v. Atul Limited [R/Tax Appeal No. 7 of 2019, dt. 10-6-2019] : 2019 TaxPub(DT) 4320 (Guj-HC), whereby the High Court held that the finding recorded by Tribunal was that no new material had surfaced on the basis of which the assessment proceedings could be reopened that, it appeared that the reopening was clearly on account of change of opinion by the AO and this is not permissible under the scheme of the Act, further this principle was well explained by this Court in the case of Gujarat Power Corporation 2013 TaxPub(DT) 409 (Guj-HC). Held: The Supreme Court not seeing any reason to interfere in the matter, dismissed the SLP leaving all the questions of law open.
REFERRED :
FAVOUR : SLP dismissed.
A.Y. :
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