CIT v. Tata Ceramics Ltd. (2018) 403 ITR 389/ 168 DTR 417 (Ker) (HC)

S.147: Reassessment-After the expiry of four years- Reassessment —Interest on deposits not disclosed in return — Details were available in the books of account or the balance-sheet or profit and loss account could not absolve the assessee from a true and correct disclosure of material facts necessary for assessment. Explanation 1 to S. 147 is applicable – Reassessment is valid [ S.148 ]

S.147: Reassessment-After the   expiry of four years- Reassessment —Interest on deposits not disclosed in return —Details were available in the books of account or the balance-sheet or profit and loss account could not absolve the assessee from a true and correct disclosure of material facts necessary for assessment. Explanation 1 to S.  147 is applicable – Reassessment is valid [ S.148 ] 

Allowing the appeal of the revenue the Court held that ,interest on deposits  was not disclosed in return  just because details were available in the books of account or the balance-sheet or profit and loss account could not absolve the assessee from a true and correct disclosure of material facts necessary for assessment. Explanation 1 to S.  147 is applicable. Reassessment was held to be  valid .( AY.1994 -95)