ACIT, Circle 1(1), Chandigarh vs. M/S Sml Isuzu Ltd., Chandigarh
ITA 644/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh18 Sept 2024AY 2015-16
Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)
For Appellant: Shri Rohit Jain, Advocate and Ms. Somya Jain, C.AFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 250Section 253Section 3
…as held that points not decided while passing assessment order u/s 143(3) is not change of opinion and that assessment was opened validly. The jurisdictional High Court judgment in case of Ropar District, Cooperative Milk Producers Union Ltd. Vs. CIT = (2009) 311 ITR 42 (P&H) relied upon. It was also pleaded that even if for argument sake, it is accepted there was disclosure by the assessee in form of note to trading and profit and loss account and balance sheet, this will not take away the jurisdiction and competency of the AO to issue notice under section 148 of the Act. On merits of the case, CIT(A) has not…