Assessing Officer cannot change nature and character of income under section 143(1) of IT Act, 1961

RELEVANT PARAGRAPH 16. On the perusal of the return of income, the statement of total income alongwith notes thereto and form no. 30 claiming refund, filed alongwith the return of income, it is clear that though the assessee had shown total income at Rs. 5,11,68,95,840, the assessee claimed its total tax liability to be Rs. Nil for the reasons given in the notes, and claimed the refund of tax that was deducted at source and deposited under section 191 of the Act aggregating to Rs. 72,67,75,771. It makes it clear that the total tax liability has been computed by the assessee at Rs. Nil in the r...