Re-assessment on the basis of CBDT circular not justified

HIGH COURT OF GUJARAT Arvind Polycot Ltd. Versus Chandra Ram SPECIAL CIVIL APPLICATION NO. 2385 OF 2001 AUGUST 27, 2012 JUDGMENT AkilKureshi J. The petitioner has challenged a notice dated 15.3.2001 issued by the respondent-Assessing Officer under section 148 of the Income-tax Act, 1961 (hereinafter to be referred to as “the Act”) seeking to reopen the assessment in case of the petitioner for the assessment year 1997-98. The petition arises in the following factual background: (1.1) The petitioner is a company registered under the Companies Act, 1956 and is regular...