https://www.taxtmi.com/caselaws?id=465245 ITAT Delhi upheld the validity of reassessment u/s 147, holding that reopening within four years on the ground that certain income was not derived from long-term finance fell within Expln. 2 to s.147 and did not constitute a mere change of opinion. The undertaking's status as a Govt. entity under a special Act did not bar reassessment. The Tribunal further sustained the CIT(A)'s power to enhance income by making disallowance u/s 14A, as dividend income had been earned without corresponding expenditure disallowance. The AO was directed to apply the same determination as in AYs 1999-2000 and 2001-02. The appeal was partly allowed for statistical purposes. en-us Thu, 21 Apr 2011 00:00:00 +0530 Fri, 12 Dec 2025 16:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465245 ITAT Delhi upheld the validity of reassessment u/s 147, holding that reopening within four years on the ground that certain income was not derived from long-term finance fell within Expln. 2 to s.147 and did not constitute a mere change of opinion. The undertaking's status as a Govt. entity under a special Act did not bar reassessment. The Tribunal further sustained the CIT(A)'s power to enhance income by making disallowance u/s 14A, as dividend income had been earned without corresponding expenditure disallowance. The AO was directed to apply the same determination as in AYs 1999-2000 and 2001-02. The appeal was partly allowed for statistical purposes. Case-Laws Income Tax Thu, 21 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465245