THE COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION & TRA vs. JOY PARTNERSHIP MINING CENTRE
ITAT/71/2018HC Calcutta15 Nov 2021
Bench: : The Hon’Ble Justice Surya Prakash Kesarwani
Section 142Section 143Section 143(3)Section 147Section 260A
depreciation of Rs.2,39,93,843/-.
15. The ITAT has allowed the cross objection of the assessee on the
preliminary issue of jurisdiction of the assessing officer for reassessment
under Section 147 of the Act, 1961 that the reassessment proceeding
was based on change of opinion. The findings recorded by the ITAT in
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this regard in paragraphs
