TaxTMI 
TaxTMI 
1982 (7) TMI 173
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....er, but the State Government directed the dealers not to charge the enhanced rate on the old stock. The order of the State Government was challenged by the assessee and, thereupon the assessee was directed to charge the enhanced rate, subject to the condition that the difference of the old and new rate would be deposited with Collector pending the decision of the higher courts. This is how, the as....
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....ed with the ITO. For doing so, he followed some other order. 2. I have carefully heard Sri Ranka, learned counsel for the assessee and the revenue. I fully agree with Shri Ranka that this is not a fit case to reopen the assessment either under clause (a) or clause (b) of section 147. My attention was drawn by Shri Ranka to the original return and the details of the difference of Rs. 16,861, which....
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....at the receipt of Rs. 16,861 was not taxable, but he changed his opinion in the reassessment order simply because the audit suggested to him to examine the entry of Rs. 16,861. I have gone through the reasons also having been recorded by the ITO. It is clear that nothing new came to the notice of the ITO and the entry of Rs. 16,861 was already brought to his knowledge at the stage of the original ....