Addl. Cit, New Delhi vs M/S. Ircon International Ltd., New ... on 22 January, 2021
5.20 We have already discussed the decisions cited by the
learned counsel of the assessee wherein the Hon'ble Court has
held change of opinion i.e. Century Textile Industries Ltd. (supra),
Tulsi Developers (supra), HK Buildcon Ltd. (supra), Nitynand
Infrastructure Ltd (supra), Replika Press Private Limited (supra),
Rasalika Trading and Investment Company Private Limited
(supra). In all these cases, queries were raised on particular issue
and same was responded by the assessee in the original
assessment proceeding and the assessment was reopened within
four years from the end of the relevant assessment year.