Section 50 applicable only on block of assets used for business and on which depreciation been claimed

Anant Raj Ltd. Vs DCIT (ITAT Delhi) Assessment order cannot contain each and every fact verified by the assessing officer and assessment cannot be reopened on the basis of mere change of opinion It is a settled law that the assessment cannot be reopened on the basis of mere change of opinion on the same set of facts on record. The Ld. DR relied on various case laws as referred above. On perusal of the same, it is seen that in those cases either new material had come to the notice of the assessing officer or there was some incorrect disclosure by the assessee in his return of income. Thus, the ...