2025 (10) TMI 315

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....BHUYAN For the Petitioner(s) Mr. Vikramjit Bannerjee, A.S.G.(NP), Mr. Raj Bahadur Yadav, AOR, Mrs. Gargi Khanna, Adv., Mr. Varun Chug, Adv., Mr. Shubhendu Anand, Adv., Mr. Aditya, Adv. For the Respondent(s) Mr. Ajay Vohra, Sr. Adv., Mr. Vaibhav Kulkarni, Adv., Mr. Aniket Deepak Agrawal, AOR. ORDER PER 1. Leave Granted. Heard both sides. This appeal is directed against an order of the H....

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.... tax for the purposes of Section 115JB; objection to reopening of concluded assessment was not disposed of; and there cannot be reopening of assessment on mere change of opinion. 4. The objections raised by the assessee to reopening of assessment were sustained by the CIT while allowing the appeal(s) vide order dated 30.06.2011 and the appeal(s) preferred by Revenue were dismissed by the Tribun....

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....document, High Court ought to have drawn adverse inference on Revenue's appeal. 7. Having regard to the reasons recorded in detail by the CIT and the Tribunal, the direction to produce the records was to test the correctness of the findings returned by the CIT and the Tribunal. When records could not be produced it could not be demonstrated that findings returned by CIT and the Tribunal were pe....