ITAT justified in accepting addition ground of validity of reassessment in terms of rule 27 of ITAT Rules

CIT Vs India Cements Ltd. (Madras High Court) Madras High Court held that assessee can raise additional ground of validity of reassessment proceedings in terms of rule 27 of the ITAT Rules. Accordingly, ITAT justified in accepting the ground that reassessment was change of opinion. Facts- AO issued independent notices u/s. 148 of the Income Tax Act, for reopening the assessment on the ground that the book profit offered by the assessee differed from the book profit prepared for the Annual General Meeting and hence certain income had escaped assessment. AO made certain additions inter alia und...