The Department issued notices under section 148 on the basis that a Singapore entity had invested in the assessee. The Department had earlier accepted similar transactions in later assessment years including scrutiny in which the foreign entity’s income was assessed. Given acceptance of the transactions and the absence of material factual differences, the High Court quashed the reassessment notices and proceedings.(AY. 2008‑09, 2011‑12)
Experion Hospitality Pvt. Ltd v. ITO (2025) 474 ITR 358 (Delhi)(HC)
S.147: Reassessment-After the expiry of four years-Share capital-Parent company-Source explained-Re assessment notice and order disposing objection quashed..[S. 68, 143(1), 143(3), 148, Art. 226]