Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Reopening of assessment u/s 147 - Keeping in view the aforesaid facts, this Court is of the view that the issue of rent of ‘A Barracks’ was within the knowledge of the Assessing Officer when he had passed the original assessment order as well as the subsequent order under Section 154 of the Act. Consequently, this Court is in agreement with the opinion of the ITAT that reassessment proceeding in the present case was based on a change of opinion and the same, therefore, cannot be sustained. - HC
Reopening of assessment u/s 147 - Keeping in view the aforesaid facts, this Court is of the view that the issue of rent of ‘A Barracks’ was within the knowledge of the Assessing Officer when he had passed the original assessment order as well as the subsequent order under Section 154 of the Act. Consequently, this Court is in agreement with the opinion of the ITAT that reassessment proceeding in the present case was based on a change of opinion and the same, therefore, cannot be sustained. - HC
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