2019 (2) TMI 1723

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...., Advocate. ORDER The Revenue is aggrieved by the order of the Tribunal rejecting its appeal. The assessee had questioned the reassessment proceedings under Sections 147/148 of the Income Tax Act, 1961 [hereafter "the 1961 Act"] on the ground that the reasons to re-open the assessment proceedings for AY 2002-03 amounted to a second opinion or review of the previous view expressed. The ass....

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....cision of the Supreme Court in CIT v. Kelvinator of India Ltd. 320 (ITR) 561 (SC) and other decisions was of the view that since this scrutiny assessment had gone into the taxability of amounts in question, the AO could not have revisited the same issue on the pretext that a binding decision was overlooked. This Court is of the opinion that the impugned order is sound and reasonable and in acco....