ITAT remands case back to AO- Reassessment based on change of opinion

Magma HDI General Insurance Co. Ltd. Vs. ITO (Calcutta High Court) Mr. Dutta could not satisfy this Court about what new material of documents came into the possession of the Assessing Officer after the order of assessment under Section 143(3) of the Act, which were not produced by the assessee before the Assessing Officer in course of regular assessment. Mr. Dutta in support of his contention also relies on Explanations (I) and (III) under Section 147 of the Act. In my considered opinion, the submission of Mr. Dutta is not convincing and acceptable and he has failed to meet the allegations of...