1995 (12) TMI 69

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....e-tax reference under section 256(2) of the Income-tax Act, 1961, at the instance of the Revenue for calling for a reference on the following two questions of law which read as under : " 1. Whether it was merely a change of opinion by the Income-tax Officer because he had considered this matter and had come to a definite conclusion, after obtaining a clarification from the assessee as contained....

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....icer came to know that the assessee had concealed substantial gain which had escaped assessment on account of compensation on, the said land amounting to Rs. 1,79,000. The Income-tax Officer submitted his proposal to the Central Board of Direct Taxes for initiation of proceedings under section 147(a) of the Income-tax Act and for issuing notice under section 148 of the Act. The Income-tax Officer ....

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....the conclusion that the opening of the assessment and reassessment proceedings are void on the ground that it was a case of mere change of opinion by the Income tax Officer and, secondly, the sanction obtained from the Board was not in accordance with law. Therefore, the Revenue has moved this application for calling for a reference on the aforesaid questions of law. We have gone through the ma....