WHEATONS DESIGN PRIVATE LIMITED,JAIPUR vs. ACIT / DCIT, CIRCLE -6, JAIPUR, JAIPUR
In the result, appeal of the assessee is allowed
ITA 781/JPR/2025[2014-15]Status: DisposedITAT Jaipur12 Nov 2025AY 2014-15
Bench: The Due Date Of Hearing.”
For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita rinesh, JCIT-DR a
Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)
…absence of any fresh material, reopening of assessment beyond four years was based on change of opinion, hence bad in law. There is no case that assessee had failed to disclose any material for purpose of assessment. State Bank of India Vs. ACIT & Ors. (2018) 172 DTR 401 (Bom.) (HC) Assessment orders passed in regular assessment proceedings do refer to examining the computation of income filed along with the return of income. Moreover, the assessment order in regular assessment proceedings in terms disallowed some of the claims made for deduction under sec. 143(3). Therefore, in the present facts, the AO has by n…