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Even Section 143(1) Assessment Cannot Be Reopened u/s 147 In Absence Of New Material
Case Law Details
- Case Name
- Delta Air Lines, INC Vs ITO (International Taxation)-2(1) (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2001-02
- Courts
- All ITAT, ITAT Mumbai
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It was held by the Third Member that section 147 applies both to section 143(1) as well as section 143(3) and, therefore, except to the extent that a reassessment notice issued u/s 148 in a case where the original assessment was made u/s 143(1) cannot be challenged on the ground of a mere change of opinion, it is open to an assessee to challenge the notice on the ground that there is no reason to believe that income chargeable to tax has escaped assessment. As regards the decision of Hon’ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers (P) Ltd. (supra) cited...
