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AO deemed to have applied his mind if facts are on record
Case Law Details
- Case Name
- CIT, Delhi Vs. M/s. Kelvinator of India Limited (Supreme Court of India)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- Supreme Court of India
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AO deemed to have applied his mind if facts are on record and reopening on change of opinion is not permissible even within 4 years
In CIT Vs Kelvinator of India Ltd. 256 ITR 1 the Full Bench of the Delhi High Court was considering a case of reopening u/s 147 within 4 years from the end of the assessment year. The Court held that when a regular order of assessment is passed in terms of section 143 (3) of the Act, a presumption can be raised that such an order has been passed on application of mind. It was held that if it be held that an order which has been passed purportedly without applicati...
