Held that reasons for reopening did not disclose any non-disclosure of facts on part of assessee during original assessment. payment of broken period interest was to be allowed as revenue expenditure. Reassessment notice is not valid. Followed American Express International Banking Corpn. v. CIT (2002) 258 ITR 601 (Bom.)(HC). (AY 2008-09)
Dena Bank v. ACIT (2022) 287 Taxman 300 / 114 CCH 299 (Bom.)(HC)
S. 147 : Reassessment-After the expiry of four years-Payment of broken period interest on acquisition of securities-Revenue expenditure-Reassessment notice is not valid. [S. 37(1), 148, Art. 226]