Shanti Prime Publication Pvt. Ltd.
Section 147 of the Income Tax Act, 1961 — Reassessment — AO raised a query once during the assessment proceedings and the asseasee has responded to that query. it would necessarily follow that the AO has accepted the assessee's submissions, so as to not deal with that issue in the assessment order. notice under section 148 on the same issue thus amounts to change of opinion which is not sustainable — Marico Ltd vs. Assistant Commissioner of income tax [2019] 311 CTR (Bombay) 865