Held that the assessee had not disclosed the amount of reimbursement of expenses claimed by it and the actual amount received by it towards reimbursement. It had not submitted the details of expenses incurred by it for verification during the assessment proceedings. The Assessing Officer had not formed any opinion regarding receipt of payments by the assessee under section 194J,which had not been shown in its profit and loss account, non-disclosure of the amount of reimbursement of expenses claimed by it, non-submission of the details of expenses incurred by it for verification during the assessment proceedings and non-production of any ledgers, bills and vouchers of expenses incurred on behalf of the principal companies. Reassessment notice is valid. (AY. 2013-14)
Distributors India (South) v. UOI (NO. 1) (2022) 446 ITR 163 / 288 Taxman 346 /(2023) 332 CTR 585(All.)(HC) Editorial : Review petition dismissed, Distributors India (South) v. UOI.(No. 2) (2022) 446 ITR 177 /(2023) 332 CTR 574(All.)(HC)
S. 147 : Reassessment-After the expiry of four years-Failure To Disclose material facts-Not disclosing receipts under Section 194J and reimbursement of expenses-Proper recording of satisfaction-Notice valid. [S. 148, 151, 194C, 194J, Form 26AS]