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Whether on the facts and circumstances of the case the Tribunal’s order in admitting the assessee’s plea under r. 27 which has jeopardised the interest of the revenue is justified in law especially when the assessee has neither filed an appeal nor a cross objection before the Tribunal ?

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Section 147 of the Income Tax Act, 1961 — Reopening of assessment beyond four year was based on change of opinion as all material being present with the AO while making original assessment under section 143(3)— Commissioner of income tax vs. India Cements Ltd [2020] 312 CTR (Madras) 168

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