VIZAG SEAPORT P.LTD,VISAKHAPATNAM vs. CIT(A) 14, MUMBAI

In the result, appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

9. Respectfully following the above judicial pronouncements, we are of the considered view that the Ld. AO has erred in reopening the assessment u/s. 147 of the Act merely by changing his opinion which is unsustainable in law and therefore deserves to be quashed. Therefore, the grounds raised by the Revenue against the order passed U/s. 143(3) r.w.s