1982 (7) TMI 173

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....some increase in the rate of fertilizer, 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 t....

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....edings before the AAC, but he concurred 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....

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....sp; with Collector In the original assessment, the difference of Rs. 17,861 was not treated to be the income of the assessee, but in the reassessment order, the ITO included the same as the income of the assessee. The argument of Shri Ranka is that it is nothing, but the case of change of opinion. He says that at the stage of the original assessment, the ITO agreed with the assessee that the re....