ITEM NO.23 COURT NO.11 SECTION XII SUPREME COURT OF INDIA RECORD OF PROCEEDINGS Petition for Special Leave to Appeal (C) No. 11574/2022 (Arising out of impugned final judgment and order dated 23-08-2021 in WA No. 2059/2021 passed by High Court of Judicature at Madras) DEPUTY/ASSISTANT COMMISSIONER OF INCOME TAX Petitioner(s) VERSUS M/S FINANCIAL SOFTWARE AND SYSTEMS PRIVATE LTD. Respondent(s) (FOR ADMISSION and I.R. ) Date : 22-07-2022 This petition was called on for hearing today. CORAM : HON'BLE MR. JUSTICE M.R. SHAH HON'BLE MRS. JUSTICE B.V. NAGARATHNA For Petitioner(s) Mr. Balbir Singh, ASG Mr. Divyanshi, Adv Ms. Meera Kaur Patel Adv Mr. Amit Sharma B, Adv Mr. Raj Bahadur Yadav, AOR For Respondent(s) UPON hearing counsel Court made following ORDER re-opening of assessment has been set aside by High Court by specifically observing that re- assessment proceedings were on change of opinion and after taking into consideration fact that at time of original assessment under Section 143 of Income-tax Act, 1961, specific queries were raised which were answered by Assessee and, therefore, thereafter it was not open for Signature Not Verified Digitally signed by R Natarajan Date: 2022.07.26 Revenue to re-open assessment proceedings on 14:46:22 IST Reason: same ground and thereafter when re-assessment proceedings Contd.. - 2 - have been set aside, it cannot be said that High Court has committed any error. Special Leave Petition stands dismissed. Pending application(s) shall stand disposed of. (NEETU SACHDEVA) (NISHA TRIPATHI) ASTT. REGISTRAR-cum-PS ASSISTANT REGISTRAR Deputy/Assistant Commissioner of Income-tax v. Financial Software and Systems Private Ltd