AO cannot take second view on same set of facts treating earlier view as erroneous

Asian Satellite Broadcast Pvt. Ltd. Vs. ITO (Bombay High Court) From the reasons recorded, order rejecting objections of the petitioner and the reply affidavit of respondent No.1 in the present proceeding, it is clearly discernible that the basis for re-opening of assessment was the two letters of departmental authorities dated 29.02.2018 and 29.03.2018. Though petitioner was not furnished copies of the said two letters, copies of the same have been annexed to the affidavit in reply wherefrom it is evident that in the case of a group entity, Commissioner of Income Tax (Appeals) had held that s...