Held that reassessment notice merely based on assessment orders of preceding years and assessee’s submission in succeeding year and there was not even a whisper of facts pertaining to assessment years under consideration. Reassessment notice is quashed. (AY. 2008-09 to 2011-12)
Bentley Nevada Inc. v. DCIT(IT) (2022) 194 ITD 10 / 94 ITR 503 (Delhi)(Trib.)
S. 147 : Reassessment-Income deemed to accrue or arise in India-Permanent Establishment-Notice based on the assessment orders of earlier years orders is held to be not valid. [S. 9(1)(i), 148]