Shri Navinchandra N. Patel, Vadodara vs. The ACIT, Circle-1(2), Vadodara
In the result, the appeal of the assessee is allowed
ITA 869/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad30 Apr 2025AY 2012-13
Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble
For Appellant: Shri Vipul Shah, ARFor Respondent: Shri R.N. Dzouza, CIT-DR
Section 143(3)Section 147Section 148Section 148(2)Section 14ASection 234BSection 250Section 271(1)(c)Section 45(2)Section 69
…ous assessment proceedings, the then Assessing Officer has applied his mind and taken a conscious decision in respect of time usage charge component and partly disallowed the claim made under Section 80IA of the Act.” iii. VXL India Ltd. vs. Asstt. CIT (1995) 215 ITR 295 (Guj), wherein it was held as under:- "4….. We are also of the view that howsoever wide the scope of taking action under s. 148 of the Act, it does not confer jurisdiction on change of opinion on the interpretation of a particular provision earlier adopted by the assessing Shri Navinchandra N Patel Vs. ACIT Asst. Year : 2012-13 - 16– authority.…