Allowing the petitions the Court held that in the absence of any new tangible material in the possession of the Assessing Officer, subsequent to the intimation under section 143(1) of the Act. Provision of Section 80CC(2) is not applicable. Reassessment was quashed. (AY.2012-13)
AMI Ashish Shah v. ITO (2022) 440 ITR 417 / 212 DTR 14/ 328 CTR 562 (Guj.)(HC)
S. 147 : Reassessment-After the expiry of four years-No tangible material-Non-Resident-Not offering the interest and bonus received on surrender of policy before maturity-Provision of Section 80CC(2) is not applicable-Reassessment was quashed [S. 10(10)(d), 80CC(2), 143(1), 148, Art. 226]