Dismissing the petition the Court held that ; On facts subsequently AO noticed that assessee had transactions with AEs which were never referred to TPO for computation of income at arm’s length. Since it was a case where assessment had been reopened on basis of tangible material placed on record, validity of reassessment proceedings deserved to be upheld .
Dolphin Drilling Ltd. v. ADIT (2018) 401 ITR 209/ 252 Taxman 181 (Uttarakhand)(HC)
S. 147 : Reassessment –With in four years- Reassessment on basis of tangible material placed on record was held to be valid [ S.44BB(3), 92CA ]