Dismissing the petitions the Court held that, under assessment of income due to misinterpretation of provision by the assessee, the reassessment notice is valid and Court cannot consider sufficiency of reason in writ proceedings. (AY. 2006-07, 2007-08, 2009-10)
Aircel Cellular Limited v. Dy. CIT (2021) 435 ITR 660 (Mad.)(HC)
S. 147 : Reassessment-With in four years-Under assessment of income-Misinterpretation of provision-Notice valid-High Court cannot consider sufficiency of reason. [S. 80IA, 148, Art. 226]