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| The Tax Publishers2019 TaxPub(DT) 0572 (Del-Trib) INCOME TAX ACT, 1961
Section 147
Where reopening was with respect to reappraisal of 'Notes on Accounts' of assessee which was there at time of original assessment, was only change of opinion.
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Reassessment - Change of opinion - Reappraisal of 'notes on accounts' of assessee which was there at time of original assessment -
It was observed by AO that there was change in accounting policy with respect to recovery of non-performing advance where assessee bank had filled suits, decree or compromised accounts. Therefore, according to AO, it had resulted into escapement of income. Commissioner (Appeals) quashed the reopening holding that additions were not made because of failure on part of assessee but due to change of opinion and there was no tangible material.Held: Reopening was with respect to reappraisal of the 'notes on accounts' of assessee which was there at time of original assessment also. Assessee-bank had disclosed all material facts to AO at time of original assessment. There was no failure on part of assessee to disclose fully and truly all material facts of computation of total income.
Followed:CIT v. Corporation Bank Ltd. (2002) 254 ITR 791 (SC) : 2002 TaxPub(DT) 52 (SC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2006-07
INCOME TAX ACT, 1961
Section 145A
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