HSBC Holdings Plc. v. Dy. CIT (2023)457 ITR 316/ 150 taxmann.com 221/ 335 CTR 427 (Telangana)(HC)

S. 147 : Reassessment-Reassessment based on materials discovered in the assessment year 2014-15-Alternative remedy-Writ petition is dismissed. [S.92CA, 144C, 148,151, Art. 226]

Dismissing the petition the Court held that there was a clear connection between the materials discovered subsequently and the belief formed by the Assessing Officer that income had escaped assessment in the assessment year 2011-12. The belief of the Assessing Officer was based on direct evidence. Therefore, it would be just and proper if the procedure prescribed under the statute was followed and in which event the assessee would have all the opportunities and remedies.(AY.2011-12)