ETHIX HEALTHCARE,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE , PARWANOO
In the result, both on the exercise of jurisdiction u/s 147 and on merits of the case, the order of the AO as well as the ld CIT(A) is hereby set-aside and matter is decided in favour of the assessee
ITA 501/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh17 Dec 2024AY 2012-13
Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)
For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri VivekVardhan, JCIT, Sr. DR
Section 139Section 143(3)Section 147Section 148Section 250Section 80Section 80I
reassessment has been initiated were already available on record and considered at length by AO while framing the original assessment under section 143(3) of the Act. It was submitted that it is clearly a case of change of opinion which is not permissible for invocation of jurisdiction under section 147 of the Act and in support reliance was placed