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“change of opinion”

ReassessmentSection 147Section 1472,292 judgments

The decision most relied on for change of opinion is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on change of opinion

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

CIT v. SFIL Stock Broking Ltd.
325 ITR 285 · 2010 · High Court
243
citing judgments

Reassessment proceedings under Section 147 are invalid and void ab initio if initiated based on 'borrowed satisfaction' without the Assessing Officer's independent application of mind, or merely on documents already available on record without fresh tangible material.

Judgments citing change of opinion

Sunil Uttam Kakade, Pune vs. ITO Ward 4(3) Pune, Pune

In the result appeal of the assessee is partly allowed

ITA 2251/PUN/2024[2017-18]Status: DisposedITAT Pune30 Jul 2025AY 2017-18

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.2251/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Sunil Uttam Kakade, V The Income Tax Officer, Roopm No.7, Bldg. No.4, S. Ward-8(3), Pune. Ashok Nagar Pimpri, Kalewadi B.O, Pune – 411017. Maharashtra. Pan: Aospk4472L Appellant/ Assessee Respondent / Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Akhilesh Srivastva –Addl.Cit(Dr) Date Of Hearing 09/07/2025 Date Of Pronouncement 30/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax (Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 31.10.2023 For A.Y.2017-18, Emanating From The Order U/S.147 R.W.S 144 Read With Section 144B Of The Act, Dated 29.03.2022. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(2)Section 144(1)(b)Section 144BSection 147Section 148Section 250Section 69A

response to notice dated 09.09.2019. 2.1 Therefore, ld.AR for the Assessee pleaded that the notice u/s.148 dated 30.03.2021 is based on change of opinion and hence, not sustainable. The ld.AR relied on the following case laws : “a. Berger Paints India Ltd. V. ACIT ([2010] 322 ITR 369 (Calcutta)) b. Commissioner ... Ward-8(5), Pune after considering the submission dropped the proceedings. Therefore, the subsequent notice u/s.148 dated 30.03.2021 is based on mere change of opinion, rather the Assessing Officer has not applied his mind while issuing the said notice dated 30.03.2021, as nowhere the Assessing Officer has referred

Anil Ramniranjan Kejriwal, Mumbai vs. Circle 24(1), Mumbai

In the result appeals filed by the assesse for assessment years 2013-14 to 2015-16 stands allowed

ITA 3336/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jul 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara()

Section 10(38)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 151Section 68

course of assessment. 4. On the facts and circumstances of the case, the reopening of assessment is resorted to merely based on change of opinion as complete details were disclosed during the course of original assessment u/s 143(3). 3 ITA No.3334, 3335, 3336/Mum/2025; A.Y. 2013-14 – 2015-16 Anil

Anil Ramniranjan Kejriwal, Mumbai vs. Circle 24(1), Mumbai

In the result appeals filed by the assesse for assessment years 2013-14 to 2015-16 stands allowed

ITA 3335/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara()

Section 10(38)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 151Section 68

course of assessment. 4. On the facts and circumstances of the case, the reopening of assessment is resorted to merely based on change of opinion as complete details were disclosed during the course of original assessment u/s 143(3). 3 ITA No.3334, 3335, 3336/Mum/2025; A.Y. 2013-14 – 2015-16 Anil

Anil Ramniranjan Kejariwal, Mumbai vs. Circle 24(1), Mumbai

In the result appeals filed by the assesse for assessment years 2013-14 to 2015-16 stands allowed

ITA 3334/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2025AY 2013-14

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara()

Section 10(38)Section 142(1)Section 143(3)Section 147Section 148Section 148ASection 151Section 68

course of assessment. 4. On the facts and circumstances of the case, the reopening of assessment is resorted to merely based on change of opinion as complete details were disclosed during the course of original assessment u/s 143(3). 3 ITA No.3334, 3335, 3336/Mum/2025; A.Y. 2013-14 – 2015-16 Anil

Vidarbha Mining Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1(3)(2), Mumbai

In the result, the appeal filed by the assessee is hereby allowed

ITA 1265/MUM/2024[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Ms. Kavitha Rajagopal, Jm & Ms. Padmavathy S., Am Vidarbha Mining Private Limited Deputy Commissioner Of Income 703, Samarpan Complex, Near Mirador Tax, Circle-1(3)(2), Mumbai Room No. 540, 5Th Floor, Aayakar Hotel, New Link Road, Chakala, Andheri (East), Mumbai – 400099. Vs. Bhavan, Maharshi Karve Rd, New Marine Lines, Churchgate, Mumbai – 400020. Pan/Gir No. Aaccv2506M (Assessee) : (Respondent) Assessee By : Shri. Gaurav Kabra Respondent By : Shri. G. J. Ninawe, Sr. Dr Date Of Hearing : 01.05.2025 Date Of Pronouncement : 30.07.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals)-Delhi (‘Ld. Cit(A) For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal & Has Also Filed Additional Grounds Which Are As Follows: Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case As Well As In Law, The Learned Cit(A) Has Erred In Confirming The Action Of Learned Assessing Officer In Reopening The Assessment U/S.147 Of The Act, Without Appreciating The Fact & Circumstances Of The Case. Vidarbha Mining Private Limited Vs. Dy. Cit

For Appellant: Shri. Gaurav KabraFor Respondent: Shri. G. J. Ninawe, SR. DR
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 153CSection 250Section 68

confirming the action of the Learned Assessing Officer in reopening the assessment u/s.147 of the Income Tax Act, 1961 on the basis of change of opinion, without appreciating the fact and circumstances of the case. The appellant prays to Your Honours' kindly allow to raise the additional ground, which ... with the materials that were already available during the original assessment proceedings which was merely 3 Vidarbha Mining Private Limited vs. Dy. CIT change of opinion by the ld. AO. The ld. AR further stated that during the scrutiny assessment the issue of capital gain on sale of mining business

Sterling Infrastructure Private Limited, Delhi vs. ACIT, Central Circle-15, Delhi

ITA 3982/DEL/2024[2014-2015]Status: DisposedITAT Delhi30 Jul 2025AY 2014-2015

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Years: 2014-15 Sterling Infrastructure Private Vs Acit, Limited, Central Circle-15, 20A, Rajpur Road, Delhi. Civil Lines, Delhi – 110 054. Pan: Aakcs7108Q (Appellant) (Respondent) Assessee By : Shri Ranjan Chopra, Advocate & Shri Jaspal Singh Sethi, Advocate Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 03.07.2025 Date Of Pronouncement : 30.07.2025 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Ranjan Chopra, Advocate &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 194CSection 196

circumstances of the case.” 3. Ld. AR has submitted that in the present case, reassessment proceedings initiated is clearly based on mere change of opinion, which is not permissible in law. The appellant had fully and truly disclosed all the material facts necessary for assessment of income for the year

M/S.Redington Distributions Pte Ltd., Singapore vs. ACIT, Intltaxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 894/CHNY/2025[2016-17]Status: DisposedITAT Chennai29 Jul 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

accordingly dismissed. 5.7 Ground Nos 6 and 7: As per these grounds, the appellant contends that the existence of PE was only a change of opinion and that all facts relevant to the dispute were provided during the assessment proceedings. As discussed in the preceding paras, the existence ... regarding these facts prior to the survey, it cannot be contended that the finding regarding existence of PE was a change of opinion. For want of adequate disclosures by the appellant, the AD did not have occasion to consider the same. It is also to be noted that the assessment

M/S.Redington Distributions Pte Ltd., Singapore vs. ACIT, Intltaxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 893/CHNY/2025[2015-16]Status: DisposedITAT Chennai29 Jul 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

accordingly dismissed. 5.7 Ground Nos 6 and 7: As per these grounds, the appellant contends that the existence of PE was only a change of opinion and that all facts relevant to the dispute were provided during the assessment proceedings. As discussed in the preceding paras, the existence ... regarding these facts prior to the survey, it cannot be contended that the finding regarding existence of PE was a change of opinion. For want of adequate disclosures by the appellant, the AD did not have occasion to consider the same. It is also to be noted that the assessment

M/S. Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 892/CHNY/2025[2014-15]Status: DisposedITAT Chennai29 Jul 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

accordingly dismissed. 5.7 Ground Nos 6 and 7: As per these grounds, the appellant contends that the existence of PE was only a change of opinion and that all facts relevant to the dispute were provided during the assessment proceedings. As discussed in the preceding paras, the existence ... regarding these facts prior to the survey, it cannot be contended that the finding regarding existence of PE was a change of opinion. For want of adequate disclosures by the appellant, the AD did not have occasion to consider the same. It is also to be noted that the assessment

M/S. Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 891/CHNY/2025[2013-14]Status: DisposedITAT Chennai29 Jul 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

accordingly dismissed. 5.7 Ground Nos 6 and 7: As per these grounds, the appellant contends that the existence of PE was only a change of opinion and that all facts relevant to the dispute were provided during the assessment proceedings. As discussed in the preceding paras, the existence ... regarding these facts prior to the survey, it cannot be contended that the finding regarding existence of PE was a change of opinion. For want of adequate disclosures by the appellant, the AD did not have occasion to consider the same. It is also to be noted that the assessment

M/S.Redington Distributors Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 890/CHNY/2025[2012-13]Status: DisposedITAT Chennai29 Jul 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

accordingly dismissed. 5.7 Ground Nos 6 and 7: As per these grounds, the appellant contends that the existence of PE was only a change of opinion and that all facts relevant to the dispute were provided during the assessment proceedings. As discussed in the preceding paras, the existence ... regarding these facts prior to the survey, it cannot be contended that the finding regarding existence of PE was a change of opinion. For want of adequate disclosures by the appellant, the AD did not have occasion to consider the same. It is also to be noted that the assessment

M/S.Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

In the result, all the appeals filed by the assessee stands allowed

ITA 889/CHNY/2025[2011-12]Status: DisposedITAT Chennai29 Jul 2025AY 2011-12

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

accordingly dismissed. 5.7 Ground Nos 6 and 7: As per these grounds, the appellant contends that the existence of PE was only a change of opinion and that all facts relevant to the dispute were provided during the assessment proceedings. As discussed in the preceding paras, the existence ... regarding these facts prior to the survey, it cannot be contended that the finding regarding existence of PE was a change of opinion. For want of adequate disclosures by the appellant, the AD did not have occasion to consider the same. It is also to be noted that the assessment

M/S. Ashok Leyland Ltd., Chennai vs. DCIT, Ncc-8(1), Ltu-II, Chennai

In the result, appeal filed by the assessee is allowed

ITA 601/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Jul 2025AY 2010-11

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 143(2)Section 143(3)Section 147Section 148Section 32(1)(iia)

emphasized that AO in absence of “tangible material” should not resort to reopening. The Hon’ble Supreme Court held that merely on “change of opinion” the AO should not re-open the assessment because he doesn’t enjoy the power to review his own order. 10. Thus, as noted before

Patel Infrastructure Limited, Ahmedabad vs. The PCIT (Central), Surat, Vadodara

In the result, appeal of the assessee is allowed

ITA 787/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad28 Jul 2025AY 2020-21

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 143(3)Section 263Section 80G

failed to verify the genuineness or eligibility of the section 80G claim is not coming from the facts and amounts to a mere change of opinion by the PCIT, which is impermissible in law under section 263 of the Act. With regards to the second issue regarding the expected credit

M/S.Mahogany Logistics Services Pvt. Ltd., Madurai vs. PCIT, Madurai-1

In the result, the appeal filed by the assessee is dismissed

ITA 1631/CHNY/2024[2018-19]Status: DisposedITAT Chennai28 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1631/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mahogany Logistics Services Vs. The Principal Commissioner Of Private Limited, Income Tax-1, 10, Jawahar Road, Chokkikulam, Madurai. Madurai 625 002. [Pan:Aafcd8781R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 30.04.2025 घोषणा की तारीख /Date Of Pronouncement : 28.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax 1, Madurai Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Company [Earlier Known As M/S. Drsr Logistics Services Private Limited] Filed Its Return Of Income For The Ay 2018-19 Claiming Loss Of ₹.31,28,98,436/- Under 2

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT
Section 139(9)Section 143(3)Section 201Section 263Section 36Section 37Section 40

change in the position adopted by the Assessing Officer after due scrutiny and examination of the facts again will constitute as ‘change of opinion’ and the same cannot be basis for initiating proceedings under section 263 of the Act and relied on the decision of the jurisdictional High Court ... therefore, the argument of revision under section 263 of the Act is not maintainable as the opinion of the ld. PCIT constitute a change of opinion, is rejected. The ld. AR placed reliance on the decision of the Hon’ble Supreme Court in the case of S.A. Builders (supra

Sylvan Greens Private Limited, Jaipur vs. Deputy Commissioner of Income Tax Circle 6, Jaipur

In the result, the appeal of the assessee is allowed

ITA 414/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Smt. Neelam Bhala, AdvocateFor Respondent: Shri Gorav Avasthi, JCIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 801C

PRIVATE LTD VS DCIT,CIRCLE-6 , JAIPUR 2. That the Ld. AO seriously erred in reopening the assessment only on the basis of change of opinion while all the material on the basis of the Ld AO reopen the assessment had already been provided during the course of scrutiny assessment ... account has already bear provided by the assessee during the course of scrutiny assessment proceedings u/s.143(3) of the Act. More change of opinion cannot be the basis to reopen the assessment under section 148 of the Act. Reply: Under explanation 1 to the provisions of Section 147 says, mere

ACIT, Circle-34, Kolkata vs. Vinod Kumar Lahoti, Kokata

In the result, the appeal of the revenue is dismissed

ITA 2460/KOL/2024[2013-14]Status: DisposedITAT Kolkata25 Jul 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 69C

during the course of original assessment proceedings the purchases were duly verified by the then AO, thus, the assessment is based merely change of opinion. The assessee has relied upon a number of judicial precedents from various courts and tribunals in support of his contentions and submissions. The submissions

S Kant Healthcare Ltd, Mumbai vs. Principal Commissionerer of Income Tax Circle -5, Mumbai

In the result, appeal of the assessee is allowed

ITA 3357/MUM/2025[2021-22]Status: DisposedITAT Mumbai25 Jul 2025AY 2021-22

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Shri V. Jani, A/RFor Respondent: Shri Swapnil Choudhary, Sr. D/R
Section 143(3)Section 263Section 80G

original assessment proceedings has to be considered as a plausible view, and the view taken by the PCIT is nothing but a change of opinion for which jurisdiction u/s 263 of the Act cannot be assumed. Considering the facts of the case in totality, we set aside the order

Bachharaj & Co Private Limited, Mumbai vs. Pr Comm. of Income Tax-3, Mumbai

In the result, appeal of the assessee is allowed

ITA 2613/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Jul 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Shri Kirit Kamdar, A/RFor Respondent: Shri Satyaprakash R. Singh, CIT D/R
Section 142(1)Section 143(3)Section 263Section 80G

original assessment proceedings has to be considered as a plausible view, and the view taken by the PCIT is nothing but a change of opinion for which jurisdiction u/s 263 of the Act cannot be assumed. Considering the facts of the case in totality, we set aside the order

Strata Geosystems (India) Private Limited, Mumbai vs. The Principal Commissioner of Income Tax -8, Mumbai

ITA 2447/MUM/2025[2020-21]Status: DisposedITAT Mumbai25 Jul 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Strata Geosystems (India) P. Ltd. Pcit Plot No. A-15/16, Sabnam 6Th Floor House, Central Cross Road B Vs. Aayakar Bhavan Midc, Andheri East M.K. Road Mumbai-400 093. Mumbai-400 020. Pan : Aaics3717K Appellant Respondent

For Appellant: Shri Prakash JotwaniFor Respondent: Shri Leyaqat Ali Aafaqui
Section 135Section 142Section 143Section 143(3)Section 2Section 263Section 37(1)Section 80Section 80G

that case dealt with reopening under Section 147, where reassessment was quashed due to absence of fresh material and being a mere change of opinion. In contrast, the present case involves revision under Section 263, where the assessment order was passed without proper inquiry into the allowability of deduction under