On writ the High Court held that assessment order under section 143(3) was passed after considering assessee’s reply to questionnaire issued by Assessing Officer regarding dividend income and even proceedings under section 263 did not raise issue of disallowance of expenditure incurred for earning exempt income under section 14A, reopening of assessment for making disallowance under section 14A was not justified. SLP of Revenue is dismissed on the ground that reasons assigned are neither satisfactory nor sufficient in law to condone the delay of 457 days (AY. 2008-09)
Dy. CIT v. Unitech Ltd. (2025) 302 Taxman 372 (SC) Editorial : Unitech Ltd v. Dy.CIT (2017) 397 ITR 547 / (2018) 99 taxmann.com 455(Delhi)(HC)
S.147: Reassessment-After the expiry of four years-Disallowance of expenditure-Exempt income-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed by High Court-Delay of 457 days-SLP of Revenue is dismissed on the ground that reasons assigned are neither satisfactory nor sufficient in law to condone the delay of 457 days. [S. 14A, 148, 263, Art. 136]
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