Pr. Commissioner of Income-tax-2 & Ors. v. State Bank of India
[Citation -2022-LL-0804-1]
| Citation | 2022-LL-0804-1 |
|---|---|
| Appellant Name | Pr. Commissioner of Income-tax-2 & Ors. |
| Respondent Name | State Bank of India |
| Court | SUPREME COURT |
| Relevant Act | Income-tax |
| Date of Order | 04/08/2022 |
| Judgment | View Judgment |
| Keyword Tags | material on record • change of opinion • reassessment proceedings |
| Bot Summary: | UPON hearing the counsel the Court made the following ORDER We have heard Mr. N. Venkataraman, learned ASG, appearing for the petitioner(s) and Mr. S.K. Bagaria, learned Senior Advocate, appearing for the respondent. Signature Not Verified We have gone through the impugned judgment and order passed by Digitally signed by R Natarajan Date: 2022.08.05 the High Court by which the High Court, vide detailed judgment and 16:49:11 IST Reason: order, has quashed and set aside the re-assessment proceedings and re-opening of the assessment in exercise of powers under Sections 2 147/148 of the Income Tax Act. From the material on record, it can be seen that the re-opening of the assessment was solely on change of opinion of the Assessing Officer and therefore, the High Court has rightly set aside the same. We see no reason to interfere with the impugned judgment and order passed by the High Court. We are in complete agreement with the view taken by the High Court setting aside the re-assessment proceedings/re-opening of the assessment. |