Y.V. Anjaneyulu v. Income Tax Officer

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The Tax Publishers1990 TaxPub(DT) 0162 (AP-HC) : (1990) 182 ITR 0242 : (1990) 089 CTR 0042 : (1990) 051 TAXMAN 0068 Y.V. Anjeneyulu v. ITO () INCOME TAX --Reassessment under s. 147----CHANGE OF OPINION--Amount settled on trust created for benefit of assessee-- Held: There was no fresh material. It was only on the audit report and subsequent order sheet that reliance was palced. Thse showed that there was no information from any rexternal source. Even the fact that an adovcate client relationship existed between the assessee and C's family was not a matter of subsequent information. The assessee has failed returns for the previous three years before the same ITO in which details of the fees that the had received from C's family were given. This was thus a clear case of change of opinion. The reassessment proceedings were as such not valid. SUBSCRIBE FOR FULL CONTENT

The Tax Publishers1990 TaxPub(DT) 0162 (AP-HC) : (1990) 182 ITR 0242 : (1990) 089 CTR 0042 : (1990) 051 TAXMAN 0068

Y.V. Anjeneyulu v. ITO ()

INCOME TAX

--Reassessment under s. 147----CHANGE OF OPINION--Amount settled on trust created for benefit of assessee--

Held:

There was no fresh material. It was only on the audit report and subsequent order sheet that reliance was palced. Thse showed that there was no information from any rexternal source. Even the fact that an adovcate client relationship existed between the assessee and C's family was not a matter of subsequent information. The assessee has failed returns for the previous three years before the same ITO in which details of the fees that the had received from C's family were given. This was thus a clear case of change of opinion. The reassessment proceedings were as such not valid.