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Siemens Product Lifecycle Management ... vs Acit, New Delhi on 22 January, 2018

In these circumstances, the subsequent order under S.147 is nothing but seeking review of completed assessment on some change of opinion on the inference earlier drawn which is to permissible in law as per the ratio laid down in Kelvinator India Ltd. (supra) and other long line of judicial precedents. Hence, in our considered opinion, the Assessing Off icer has misdirected himself in law in reopening the completed assessment without any legal f oundation. In this view of the matter, impugned assessment made under S.143(3) read with S.147 of the Act is liable to be set aside cancelled. We do so accordingly."
Income Tax Appellate Tribunal - Delhi Cites 19 - Cited by 9 - Full Document
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