ASHOK VIJAYKUMAR KOTECHA,JALGAON vs. ACIT, CIRCLE 1, JALGAON, JALGAON
In the result, the appeal filed by the assessee is partly allowed
ITA 1453/PUN/2023[2011-12]Status: DisposedITAT Pune24 Feb 2025AY 2011-12
Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2011-12
For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Uma Shankar Prasad
Section 143(3)Section 147Section 148Section 153A
reassessment proceedings when admittedly conditions specified u/s 147 of the ITA, 1961 for valid initiation were not satisfied in as much as all the facts were truly and fully disclosed in the original assessment proceedings and order was passed after due verification. As such, the addition was only the result of a change in opinion and the action