164 results for “reassessment u/s 147”+ Section 131(3)clear
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Bench: Shri Pramod M Jagtap & Ms. Madhumita Roy
reassessment has to be based on fulfilment of certain pre-condition and if the concept of "change of opinion" is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of "change of opinion" as an in-built test to check abuse of power