Allowing the petition the Court held that there was no such material on record to indicate that assessee had actually received any interest on capital and remuneration from partnership firm and, thus, question of taxing same did not arise at all-Whether, therefore, impugned reopening notice was unjustified and same was to be set aside.
Devenbhai Mafatlal Patel v. ACIT (2021) 278 Taxman 198 / 199 DTR 298 / 318 CTR 722 (Guj.)(HC)
S. 147 : Reassessment-Firm-Remuneration-Not received any interest or remuneration-Notice for reopening of assessment is held to be not justified. [S. 10AA, 148, Art. 226]