The tribunal case of Bhageria Finance & Investment Pvt Ltd vs. ITO focuses on the invalidity of reassessment proceedings for the assessment year 2010-11. The key issue revolves around the reopening of the case under section 147/148 of the Income Tax Act without substantial new evidence, making the reassessment void ab initio.
The article will explore the various legal arguments made by the appellant challenging the reassessment and the supporting judgments cited. The tribunal’s decision to quash the reassessment on the grounds of it being initiated without new material and merely based on a change of opinion will be critically analyzed.
This case sheds light on the procedural aspects of tax reassessments and the protections available to taxpayers against arbitrary decisions by tax authorities. The implications of this case for the interpretation of sections 147 and 148 of the Income Tax Act are significant for both tax professionals and taxpayers.
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