Reopening based on Change of opinion is invalid; HC dismisses Appeal in Airtel case

Principal CIT Vs. Bharti Airtel Ltd. (Delhi High Court) 1. The Revenue is aggrieved by the order of the ITAT which set aside the re-assessment order made by the Assessing Officer. 2. The facts are that the assessee filed the return for AY 2002- 2003. This was assessed under the normal provisions of the Income Tax and at book profit of Rs. 1,05,53,29,112 under Section 115JB through an order finalized under Section 153 (3). This was after the Assessing Officer considered the claim by the assessee to treat software expenses to the tune of Rs. 5.44 crores as administrative and other expendit...