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1 - 10 of 34 (0.67 seconds)Section 22 in The Income Tax Act, 1961 [Entire Act]
Section 34 in Income Tax Rules, 1962 [Entire Act]
Section 9 in The Income Tax Act, 1961 [Entire Act]
Section 9 in Income Tax Rules, 1962 [Entire Act]
Commissioner Of Income-Tax, Bombay ... vs H. Holck Larsen on 12 August, 1971
Therefore, if there is new knowledge or new information and such knowledge leads to a change of opinion, then, in our opinion, as was observed by the court in the case of CIT v. H. Hoick Larsen [1972] 85 ITR 467 (Bom) that would not be a case of mere change of opinion but it would be a change of opinion supported by or in consequence of the knowledge received by the ITO and such a change of opinion will not be outside the scope of Clause (b) of Section 147 of the I.T. Act, 1961. As, in this case, there was such an information or knowledge that the original assessment might have been wrong and the ITO because of that information had to re-examine the facts of this case and formed the belief that the income had escaped assessment, in our opinion, it cannot be said that the proceedings were not validly initiated. In the premises, the question No. 1 referred to this court must be answered in the affirmative and in favour of the revenue.