https://www.taxtmi.com/caselaws?id=306620 The Tribunal invalidated the assessment made under section 143(3)/147, ruling that the reopening was based on a mere change of opinion and did not meet the requirements of the first proviso to section 147. Consequently, the disallowance of provision towards warranty expenses and the disallowance of set off of brought forward losses from the amalgamating company were not adjudicated upon, rendering them infructuous. The Revenue's appeal was dismissed, and the assessee's Cross Objection was allowed. en-us Wed, 07 Sep 2016 00:00:00 +0530 Wed, 15 Feb 2023 08:51:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306620 The Tribunal invalidated the assessment made under section 143(3)/147, ruling that the reopening was based on a mere change of opinion and did not meet the requirements of the first proviso to section 147. Consequently, the disallowance of provision towards warranty expenses and the disallowance of set off of brought forward losses from the amalgamating company were not adjudicated upon, rendering them infructuous. The Revenue's appeal was dismissed, and the assessee's Cross Objection was allowed. Case-Laws Income Tax Wed, 07 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306620