Case Law Details
CIT vs Kelvinator of India Ltd. (Delhi High Court -Full Bench) [2002] 256 ITR 1/123- 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 application of mind would itself confer jurisdiction upon the Assessing Officer to reopen the proceeding without anything further, the same would amount to giving premium to an authority exercising quasi-judicial function to take benefit of its own wrong. It was held that section 147 of the Act does not postulate conferment of power upon the Assessing Officer to initiate reassessment proceedings upon a mere change of opinion.
Also Read-
CIT, Delhi Vs. M/s. Kelvinator of India Limited (Supreme Court of India)
Delhi High Court
Commissioner Of Income-Tax
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