Digi1 Electronics (P.) Ltd. v. ACIT [2023] 458 ITR 478/148 taxmann.com 184 / 292 Taxman 242 (Bom)(HC)

S. 147 : Reassessment – After the expiry of four years – Cash deposits -Insights portal that certain high risk transactions had taken place in case of assessee which were needed to be verified-No failure to disclose material facts – Re assessment notice and order disposing the objection was quashed. [S. 68, 143(3), 148, Art. 226]

 Allowing the petition, the Court held that reopening notice was issued on ground that an information was received on insights portal that certain high risk transactions had taken place in case of assessee which were needed to be verified, since as per reasons itself transactions were to be verified and, further, there was no live link or nexus between said information received and income escaping assessment, impugned reopening notice issued after four years from end of relevant assessment year was unjustified. Reassessment notice and order disposing the objection was quashed. (A.Y. 2016-17)