2018 (2) TMI 1214

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.... Section 147 of the Income Tax Act, 1961 (for short "Act"). The appellant was concerned with the assessment year 2005-06, which was finalised by the 3rd respondent, the Assessing Officer, as per Ext.P1 dated 24-12-2007 under Section 143(3) of the Act. Proceedings were initiated under Section 154 of the Act, which stood finalised as per Ext.P2 order. Appeals are pending against Exts.P1 and P2 orders before the first appellate authority. 2. While so, by Ext.P6 notice dated 29-03-2012, the 3rd respondent initiated proceedings under Section 148 of the Act proposing to effect re-assessment under Section 147. Ext.P6 notice indicates that the re-assessment was proposed without any reasons shown. The appellant then filed Ext.P7 requesting for the....

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....icated to the appellant. There could be no allegation of change of opinion by way of review, was the specific finding. Taking the view that the assessee is mainly agitating a question of fact, which can be brought to light on furnishing the export turnover details; the assessee was relegated to the assessment proceedings. 5. The contention raised before this Court by the appellant is also that the specific amount which is now sought to be disallowed, was earlier disallowed in the assessment order. The assessment order is seen at Ext.P1. In paragraph 8 of Ext.P1, a dis-allowance of Rs. 1,53,95,507/- was made out of the total claim of deduction of Rs. 15,41,91,530/- under Section 10B. The appeal memorandum as seen from Ext.P3 also, in parag....