Reassessment to disallow claim allowed earlier by change of opinion not permissible

HIGH COURT OF DELHI Commissioner of Income-tax versus Maruti Suzuki India Ltd. Income Tax Appeal No. 1232 of 2009 Date of Pronouncement – 18.10.2012 JUDGMENT S. Ravindra Bhat, J. In this appeal the revenue challenges the Income Tax Appellate Tribunal’s (hereafter “Tribunal”) order dated 12.12.2008 by which it allowed the assessee’s appeal, quashing the reassessment proceedings instituted against it under section 147, Income-tax Act, 1963. 2. The relevant facts are that the assessee filed original return of income on 30.11.98 which was revised o...