https://www.taxtmi.com/caselaws?id=22360 The court ruled in favor of the assessee on all issues. It held that the firm's activity, constituted by two doctors, did not amount to business as per the Income-tax Act. The Income-tax Officer's action under section 147(b) based on an audit objection was deemed a 'change of opinion', contrary to the Revenue's position. Additionally, the court found that section 64(1)(i) was not applicable to the professional firm of the doctors, emphasizing the distinction between business and profession and the legislative intent behind the provision. en-us Mon, 11 Feb 1991 00:00:00 +0530 Wed, 09 Dec 2009 14:21:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22360 The court ruled in favor of the assessee on all issues. It held that the firm's activity, constituted by two doctors, did not amount to business as per the Income-tax Act. The Income-tax Officer's action under section 147(b) based on an audit objection was deemed a 'change of opinion', contrary to the Revenue's position. Additionally, the court found that section 64(1)(i) was not applicable to the professional firm of the doctors, emphasizing the distinction between business and profession and the legislative intent behind the provision. Case-Laws Income Tax Mon, 11 Feb 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22360