Adani Power Maharashtra Ltd. v. ACIT (2023)454 ITR 720 (Guj)(HC) Adani Power Rajasthan Ltd v. ACIT (2023)454 ITR 734/ 292 Taxman 475 (Guj)(HC)

S. 147 : Reassessment-Within four years-Audit objection-Question of law-Notice and order disposing the objection was quashed. [S. 148, Art, 226]

On allowing the petition the Court held that the audit party had expressed its opinion on a question of law. It had also pointed it out to the Assessing Officer and that information which had been given was on question of law. The Assessing Officer had in clear terms stated that the objections raised by the audit party had been examined carefully and found to be not acceptable. The Assessing Officer had no subjective satisfaction while issuing the notice of reopening the assessment that income had escaped assessment. The notice of reassessment was not valid. (AY. 2017-18) (2016-17)