https://www.taxtmi.com/caselaws?id=753264 The Calcutta HC held that reassessment proceedings under Section 147 were valid as the original assessment order was silent on Section 115JB liability. The assessing officer had neither formed any opinion nor applied mind regarding book profit tax liability under Section 115JB in the original assessment. Since the original order was non-speaking and cryptic on this provision, the reassessment was not based on change of opinion but on income that escaped assessment. The ITAT's finding that reassessment was based on change of opinion was held perverse and unsustainable. The matter was decided in favour of revenue. en-us Tue, 21 May 2024 00:00:00 +0530 Tue, 18 Jun 2024 18:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753264 The Calcutta HC held that reassessment proceedings under Section 147 were valid as the original assessment order was silent on Section 115JB liability. The assessing officer had neither formed any opinion nor applied mind regarding book profit tax liability under Section 115JB in the original assessment. Since the original order was non-speaking and cryptic on this provision, the reassessment was not based on change of opinion but on income that escaped assessment. The ITAT's finding that reassessment was based on change of opinion was held perverse and unsustainable. The matter was decided in favour of revenue. Case-Laws Income Tax Tue, 21 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753264