https://www.taxtmi.com/caselaws?id=61222 The Tribunal dismissed the Revenue's appeal, upholding the CIT (A)'s decision that the assessment under section 147(b) was invalid. The Tribunal found that all relevant facts were known during the original assessment, and the audit note did not constitute new information. Emphasizing that challenging based on the audit note amounted to a change of opinion, the Tribunal sided with the assessee, affirming the exemption claimed under sections 80P(2)(a)(iii) and 80P(2)(a)(iv). en-us Thu, 14 Jul 1988 00:00:00 +0530 Tue, 11 Jan 2011 13:38:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61222 The Tribunal dismissed the Revenue's appeal, upholding the CIT (A)'s decision that the assessment under section 147(b) was invalid. The Tribunal found that all relevant facts were known during the original assessment, and the audit note did not constitute new information. Emphasizing that challenging based on the audit note amounted to a change of opinion, the Tribunal sided with the assessee, affirming the exemption claimed under sections 80P(2)(a)(iii) and 80P(2)(a)(iv). Case-Laws Income Tax Thu, 14 Jul 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61222