Dismissing the petition the Court held that the reopening was post four years and therefore, notice need not be issued as full facts had been disclosed by the assessee. The assessee was not required to state the law, which the Department felt may be attracted. (AY. 2012-13)
ACIT v. Oracle Financial Services Software Ltd. (2023) 452 ITR 280 (SC) Editorial: Oracle Financial Services Software Ltd. v. ACIT (No. 2) (2023) 452 ITR 279 (Bom)(HC), affirmed.
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Assessee is not required to state law which department feels attracted. [S. 148, Art. 136]