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Showing contexts for: raw material gas in Commissioner Of Income-Tax, ... vs Indian Plastics & Chemicals P. Ltd. on 5 February, 1979Matching Fragments
4. The learned counsel for the assessee has invited our attention to the definition of the term "petrochemical" in the Condensed Chemical Dictionary (8th Edn.) revised by Gessner G. Hawley. According to that dictionary, the meaning of that term is "an organic compound for which petroleum or natural gas is the ultimate raw material". The learned standing counsel did not dispute that for manufacturing synthetic resins, petroleum or natural gas is the ultimate raw material. We do not see how a mere change of opinion on this point by the ITO, even if it be on the basis of a circular issued by the CBDT or the memorandum issued by the Commissioner, he (the ITO) could reopen the assessment under s. 147(b).