Case Law Details
Ultra Tech Cement Ltd Vs CIT (ITAT Mumbai)
ITAT Mumbai held that change of opinion is not permissible under the garb of reopening of assessment under section 147/148 of the Income Tax Act.
Facts- The assessee being a public limited company is into manufacturing and trading and sale of cement filed its return of income for the year under consideration declaring total income at Rs.2284,05,32,680/-, there after filed revised return at total income of Rs.2283,30,74,150/-. On the basis of search and seizure operation carried out u/s. 132 of the Income Tax Act at the premises of Aditya Birla Management & Corporation Pvt. Ltd. notice u/s. 153C of the Act was issued on the assessee for A.Y. 2008 – 09 to 2013-14 including the year under consideration.
AO by recording reasons for reopening issued notice u/s. 148 of the Act. After considering the contentions and submissions raised by the assessee the AO proceeded to frame the assessment by making different additions/ disallowance of deductions framed the assessment u/s. 143(3) read with Section 147 of the Act.
CIT(A) partly allowed the same. Being aggrieved, the present appeal is filed.
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