ITAT declares Reopening u/s 147 Invalid due to Lack of Fresh Tangible Material [Read Order]
Referring to legal precedents, the ITAT ruled that merely reassessing the same issues without fresh material amounted to a change of opinion, which is impermissible under the law
The Ahmedabad Bench of Income Tax Appellate Tribunal ( ITAT ) declared the reopening of the assessment under Section 147 of the Income Tax Act,1961,invalid due to the lack of fresh tangible material. Cadila Pharmaceuticals Limited,appellant-assessee,was a manufacturer of pharmaceuticals and hospital products. It initially filed a return for the assessment year 2011-12 on 30.11.2011,…
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