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Reopening to further disallow expenses under section 14A on change of opinion is invalid
Case Law Details
- Case Name
- Sandesh Procon LLP Vs ACIT (Gujarat High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All High Courts, Gujarat High Court
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Sandesh Procon LLP Vs ACIT (Gujarat High Court)
A bare perusal of the reasons and original the assessment order made under Section 143(3) of the Act, the facts emerge that, the respondent authority had determined the issue of disallowance after considering the material available and now again without any tangible material available with the Assessing Officer based on the same materials, which were relied at the time of original assessment proceedings, has reason to believe that there is escapement of income. Therefore, in this circumstances, we are of the view that, the material available with...
