CIT v. Foramer France

Commissioner of Income Tax, Delhi VIII vs. Indian Farmers Fertilizers Co-Op. Ltd

The appeal stands disposed of accordingly

…REPORTED * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA No. 740/2008 COMMISSIONER OF INCOME TAX, DELHI-VIII .....Appellant Through: Ms. Prem Lata Bansal, Advocate versus INDIAN FARMERS FERTILIZERS CO-OP. LTD. .....Respondent Through: Mr. Satinder S. Gulati and Mr. Kamaldeep Gulati, Advocates % Date of Decision : December 24, 2010 CORAM: HON’BLE MR. JUSTICE A.K. SIKRI HON'BLE MS. JUSTICE REVA KHETRAPAL 1. Whether reporters of local papers may be allowed to see the judgment? 2. To be referred to t…

Commissioner of Income Tax vs. Xerox Modicorp Limited

Appeals are dismissed

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MS. JUSTICE REVA KHETRAPAL

…sing quasi judicial function to take benefit of its own wrong. Hence, section 147 of the Act does not postulate conferment upon the AO to initiate reassessment proceedings upon a mere change of opinion. In the case of CIT Vs. Foramer France reported in 264 ITR 566 the Hon‟ble Supreme Court has approved the judgment of the Hon‟ble Allahabad High Court and has held that the assessment cannot be reopened on the basis of mere change of opinion and the amendment of section 147 introduced with effect from 1.4.89 has not altered the position. In as much as that even under the amended provisions the issue…

Commissioner of Income Tax vs. Xerox Modicorp Limited

Appeals are dismissed

…authority exercising quasi judicial function to take benefit of its own wrong. Hence, section 147 of the Act does not postulate conferment upon the AO to initiate reassessment proceedings upon à mere change of In the case of CIT Vs. Foramer France reported in 264 ITR 566 the Hon'ble Supreme Court has approved the judgment of the Hon'ble Allahabad High Court and has held that the assessment cannot be reopened on the basis of mere change of opinion and the amendment of section 147 introduced with effect from 1.4.89 has not altered the position. In as much as that even under the amended provisions the issue cannot b…

Commissioner of Income Tax Central I vs. Xerox Modicorp Ltd

Appeals are dismissed

…authority exercising quasi judicial function to take benefit of its own wrong. Hence, section 147 of the Act does not postulate conferment upon the AO to initiate reassessment proceedings upon a mere change of In the case of CIT Vs. Foramer France reported in 264 ITR 566 the Hon'ble Supreme Court has approved the judgment of the Hon'ble Allahabad High Court and has held that the assessment cannot be reopened on the basis of mere change of opinion and the amendment of section 147 introduced with effect from 1.4.89 has not altered the position. In as much as that even under the amended provisions the issue cannot b…

Commissioner of Income Tax vs. Xerox Modicorp Limited

Appeals are dismissed

…sing quasi judicial function to take benefit of its own wrong. Hence, section 147 of the Act does not postulate conferment upon the AO to initiate reassessment proceedings upon a mere change of opinion. In the case of CIT Vs. Foramer France reported in 264 ITR 566 the Hon‟ble Supreme Court has approved the judgment of the Hon‟ble Allahabad High Court and has held that the assessment cannot be reopened on the basis of mere change of opinion and the amendment of section 147 introduced with effect from 1.4.89 has not altered the position. In as much as that even under the amended provisions the issue…