INCOME TAX OFFICER, MUMBAI vs. SVADESHI ENTERPRISE(HUBLI), MUMBAI
In the result, appeal filed by the revenue is dismissed
ITA 2785/MUM/2023[2014-15]Status: HeardITAT Mumbai03 May 2024AY 2014-15
Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Rahul Chaudhary, Hon'Bleincome Tax Officer V. Svadeshi Enterprise(Hubli) R.N. 234, 2Nd Floor 12/A Yusuf Building Kautilya Bhawan, Bkc Veer Nariman Road, Fort Mumbai, Maharashtra- 400051 Mumbai-400023 Pan: Aapfs0181B (Appellant) (Respondent) Assessee Represented By : Shri Vijay Mehta Shri Veerbhandra Mahajan Department Represented By :
Section 143(1)Section 143(3)Section 147Section 148
…ment under s. 147 merely because there is a change of opinion cannot be allowed. In our opinion, therefore, in the present case also, it was not permissible for respondent No. 1 to issue notice under s. 148.” 11. In the case of CIT v. Aroni Commercial Ltd., [393 ITR 673] the Hon’ble Jurisdictional High Court of Bombay was seized with the following substantial question of law: - “(i) Whether on the facts and circumstances of the case, the Tribunal was correct in law in treating the reopening of the case as bad in law by holding it to be a mere change of opinion without appreciating the fact that the notice u/s 1…
