Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Validity of Reopening of assessment u/s 147 - entitlement to exemption u/s 54F - The High Court examines Section 54F of the Act and concludes that the reassessment is based on a mere change of opinion, as the same facts were considered in previous assessments without disallowing the exemption under Section 54F.- Referring to the decision in Calcutta Discount Company Ltd. vs. Income Tax Officer, the Court holds that the petitioner is entitled to relief under Article 226 of the Constitution due to lack of jurisdiction by the Assessing Officer.
Validity of Reopening of assessment u/s 147 - entitlement to exemption u/s 54F - The High Court examines Section 54F of the Act and concludes that the reassessment is based on a mere change of opinion, as the same facts were considered in previous assessments without disallowing the exemption under Section 54F.- Referring to the decision in Calcutta Discount Company Ltd. vs. Income Tax Officer, the Court holds that the petitioner is entitled to relief under Article 226 of the Constitution due to lack of jurisdiction by the Assessing Officer.
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