2019 (6) TMI 615

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.... Assessee is a company engaged in manufacturing pharmaceuticals, fertilizers, chemicals, paints etc. The company filed its return on income for Assessment Year 2007- 08 declaring total income Nil (under normal provisions) and Rs. 23,36,35,281/- (under MAT) on 27.10.2007. The Income Tax return was assessed under Section 143(3) of the Act read with Section 144(c) of the Act declaring the total income of Rs. 23,22,62,069/- (under normal provisions) or Rs. 23,80,65,281/- (under MAT provisions) on 23.02.2011. 3. It appears that the Assessing Officer thought fit to reopen the assessment. The assessee raised its objections to the same. the stance of the assessee was that it was merely a case of change of opinion on the basis of which the assessm....

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....hem to be revenue in nature?" 7. Having heard Mr. M. R. Bhatt, the learned Senior Standing Counsel appearing for the appellant and having gone through the materials on record, we are of the view that no substantial question of law is involved in the present appeal. The issue appears to be squarely covered by a decision of this court in the case of Gujarat Power Corporation Ltd. Vs. ACIT [2013] 350 ITR 266 (Guj.). We quote the relevant observations made by the Tribunal in the impugned order. "5. We find that the issue is now covered, in favour of the assessee, by the judgment of the Hon'ble jurisdictional High Court in the case of Gujarat Power Corpn, Ltd. Vs. ACIT, [2013] 350 ITR 266 (Guj.), wherein Their Lordships have held that m....