TaxTMI 
TaxTMI 
2022 (1) TMI 1356
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....spondent : Mr. Sham V. Walve, Advocate ORDER P.C.: 1. Petitioner is impugning a Notice dated 19.03.2020 issued under section 148 of the Income Tax Act, 1961 (said "Act") for AY 2013-14, seeking to reopen Petitioner's assessment. The notice has been issued after expiry of four years from the relevant Assessment Year and in this case, assessment under section 143(3) has also been completed. There....
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....espondents have failed to prove that there was any failure by Petitioner to truly and fully disclose material facts. 3. Moreover, the notice to reopen is issued purely based on change of opinion. This is because the Assessing Officer, prior to passing the original assessement order raised a query vide communication dated 23 November, 2015, specifically raising a query regarding this Company, Conf....
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.... 8. Whether the promoters of M/s. Confidence Finance & Trading Ltd., are you relative or friends. You are required to comply with the above details within seven days of receipt of this letter." 4. Petitioner replied by its letter 30 November, 2015. This letter was exhaustive and contains every detail that the Assessing Officer had called for. Thereafter, the Assessment Order dated 29 January, 2....
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....ery issue of Petitioner entering into transactions, relating to the scrip of Confidence Finance & Trading Ltd., was a subject of consideration by the Assessing Officer during the original assessment proceedings. It would, therefore, follow that re-opening of the assessment by the impugned notice is merely on the basis of change of opinion of the Assessing Officer from what held earlier during the ....