S. 147: Reversal of law by Supreme Court does not justify reopening

When the assessment order was passed, the law as declared by the jurisdictional High Court was that the civil construction work carried out by the assessee would be entitled to the benefit of s. 80HH. This was reversed in CIT vs. N.C. Budharaja 204 ITR 412 (SC). The subsequent reversal of the legal position by the judgment of the Supreme Court does not authorise the Department to reopen the assessment, which stood closed on the basis of the law, as it stood at the relevant time

 DCIT vs. Simplex Concrete Piles (India) Ltd (Supreme Court)