The Hon’ble high court quashed and set aside the reassessment notice on the basis that even after the proposed addition, there would not be any taxable income impact due to Sec. 115JB. Revenue pursued SLP but offered no justifiable grounds to condone a 196-day delay in filing. SLP dismissed on account of failure to explain the delay. (AY. 2017-18)
ACIT v. Adeshwara Cement Co. (P.) Ltd. (2025) 306 Taxman 271 (SC) Editorial : Adeshwara Cement Co. (P.) Ltd v.ACIT (2024) 166 taxmann.com 583 (Guj)(HC)
S. 147 : Reassessment-With in four years-Cash credits-Book profit-Even if the proposed addition is made, there would be no taxable income-Reassessment notice was quashed by High Court-SLP delay of 196 days-Delay was not condoned-SLP dismissed.[S. 68, 115JB, 148, Art. 136]
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