Halite Personal Care India (P.) Ltd. v. DCIT (2022)448 ITR 303/ 218 DTR 531/ 286 Taxman 464 (Bom.)(HC)

S. 147 : Reassessment-After the expiry of four years-Provision for sales and operating expenses-No failure to disclose material facts-Reassessment notice was not valid. [S. 148, Art, 226]

Allowing the petition the Court held that  the assessee provided all details called for including breakup of various expenses like provisions for sales return and other operating expenses and assessment was completed accordingly. All points, which had been raised in reasons for reopening, were raised by Assessing Officer during original assessment proceedings and all documents and details were provided to Assessing Officer. Reassessment notice was not valid.  Relied on  3I Infotech Ltd v. ACIT (2010) 329 ITR 257 ( Bom)(HC), Cromton Greaves Ltd v. ACIT ( 2015) 55 taxmann.com 59 / 229 Taxman 545/ 275 CTR 49  (Bom)(HC)     (AY. 2012-13)