Dr. Sajan Hedge v. ACIT (2021) 283 Taxman 144/ (2022) 440 ITR 389 (Mad.)(HC)

S. 147 : Reassessment-After the expiry of four years-Method of accounting-Professional income-Notice issued on the basis of statement of a manger (Operations)-Re assessment notice is held to be justified. [S. 145, 148, Art. 226]

Reassessment notice was issued  on ground that a statement of  manager (operations) in hospital in which assessee was practicing was recorded in which he stated that on basis of number of patients visited to assessee, income from consultation fees received by assessee from hospital practice was much more than what was shown by assessee. On writ the Court held that  reason for reopening of assessment was made available to assessee, while disposing of objections, Assessing Officer had categorically stated that he had reason to believe that income chargeable to tax had escaped assessment.   Reassessment notice was held to be justified. (AY. 2012-13, 2015 -16, 2016 -17 ) (SJ)