Allowing the petition the Court held that there was a complete disclosure of all primary material facts on part of assessee in course of assessment as regards the allowability of advertisement and sale promotion as revenue expenditure. Accordingly reassessment proceedings merely on basis of change as of opinion was not justified . (AY. 2011-12)
Asian Paints Ltd. v. Dy. CIT (2019) 261 Taxman 380 (Bom.)(HC) Editorial: SLP of revenue is dismissed, Dy.CIT v. Asian Paints Ltd (2020) 269 Taxman 104 (SC)/ Review petition of revenue was dismissed Dy.CIT v. Asian Paints Ltd ( 2020) 277 Taxman 206 (SC)
S. 147 : Reassessment–Business expenditure–Capital or revenue- Advertisement and sales promotion- Complete disclosure of all primary material facts on part of assessee in course of assessment- Reassessment proceedings merely on basis of change of opinion was not justified [ S.37(1) , 148]