Case Law Details
PCIT Vs Central Cottage Industries Corporation of India Ltd (Delhi High Court)
This Court is of the view that the issue of rent of ‘A Barracks’ was within the knowledge of the Assessing officer when he had passed the original assessment order as well as the subsequent order under Section 154 of the Act. Consequently, this Court is in agreement with the opinion of the ITAT that reassessment proceeding in the present case was based on a change of opinion and the same, therefore, cannot be sustained.
FULL TEXT OF THE JUDGMENT/ORDER OF DELHI HIGH COURT
1. Present Income Tax Appeal has been filed challenging the Order August, 2019 passed by the Income Tax Appellate Tribunal (‘ITAT’) in ITA No. 1781/Del/2015 for the Assessment Year 2007-08.
2. Learned counsel for the Appellant states that the ITAT has erred in not considering the fact that the original assessment order passed under Section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’) did not address or express any opinion on the issue of rent payable on the basis of which reassessment had been initiated.
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