ANIL RAJ TULI Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) The challenge in the present petition is to a notice dtd. 30/3/2021 issued by the Income Tax Officer (ITO), Bargarh Ward, Bargarh under Sec. 148 of the Income Tax Act, 1961 (the Act) seeking to reopen the assessment for the Assessment Year (AY) 2014-15.

(2.) The main ground on which the notice is challenged is that it has been initiated after the expiry of four years from the end of the relevant AY on a mere change of opinion without any tangible new material.

(3.) The background facts are that on 29/10/2014, the Petitioner filed his return of income for the AY 2014-15 showing a total income of Rs.10,81,300.00. The return was picked up for scrutiny and the statutory notices under Ss. 143(2) and 142(1) of the Act were issued. The Petitioner with the return submitted his balance sheet as of 31/3/2014, and trading and profit and loss account accompanied by the audit report in Form-3CB.