2021 (4) TMI 26

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....thil Kumar, Senior Standing Counsel For the Respondent : no appearance JUDGMENT M.DURAISWAMY, J. Challenging the order passed in I.TA.No.1795/Mds/2013 in respect of the assessment year 2004-05 on the file of the Income Tax Appellate Tribunal, Chennai, "A" Bench, the Revenue has filed the above appeal. 2.The appellant - Revenue has raised the following substantial questions of law in the groun....

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....me Tax held that the re-opening, in question, is mere change of opinion. Admittedly, the impugned assessment year is 2004-05. The re-opening notice was issued on 28.03.2011 (i.e.) beyond the period of four years from the end of the relevant assessment year (i.e.) 31.03.2005. As per proviso to Section 148, it is clear that in the case of re-opening made beyond four years from the end of the relevan....