2009 (7) TMI 47

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....IBRAHIM KALIFULLA, J. - The Revenue has come forward with the above appeal, raising the following substantial question of law: "Whether in the facts and circumstances of the case, the Tribunal was right in holding that the re-assessment proceedings under Section 147 to re-compute the deduction allowable under Section 80HHC in accordance with Section 801B(13) and 801A(9) was only a change on opini....

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....ee to make a return under Section 139 or in response to a notice issued under sub-section (1) of Section 142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year. 3. It is not the case of the appellant that the present case falls under any of the exceptions set out in the said provision. The assessment is related to the year 2001....