2017 (8) TMI 727

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....rtains to Assessment Year 2005-06. 2] Mr.Suresh Kumar, the learned counsel for the Appellant submits that the Tribunal was not justified in annulling the Assessment, reopened under Section 148 of the Income Tax Act, 1961 (for short "the Act"), on the ground of change of opinion by the Assessing Officer, without appreciating the fact that the Assessment was reopened on the basis of reasons to be....

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....see and allowed setof of loss arising on sell of housing loan portfolio. Merely because the another Assessing Officer has a different opinion cannot be a ground to reopen assessment and so also on the reason of audit object remedial action by initiating reopening proceeding cannot be resorted to as held by the Apex Court in case of Indian and Eastern Newspaper Society vs. CIT, reported in 119 ITR ....