Bombay HC: AAR’s Different View Not Ground for Reopening Assessment

Usha Eswar Vs Rajeshwari Menon (Bombay High Court) Bombay High Court held that different view by Authority of Advance Ruling (AAR) in case of another Applicant cannot be ground for reopening of assessment under section 147 of the Income Tax Act. Facts- Petitioner is challenging the legality and validity of notices issued under Section 148 of the Income Tax Act, 1961 (the ‘Act’) issued by Respondent No.1 for Assessment Years 1997-98, 1998-99, 1999-200 and 2000-2001. It is Petitioner’s case that these notices had been issued without satisfying the jurisdiction condition necessary to make a...