ICICI Bank Ltd. v. DCIT [2025] 171 taxmann.com 617 (Bom) (HC)

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment quashed.[S. 36(1)(vii), 148, Art. 226]

Where assessment was reopened after expiry of four years from the end of the relevant assessment year on the ground that the assessee had misrepresented deductions claimed under sections 36(1)(vii) and 36(1)(viia), the Assessing Officer having already raised a query during the original assessment regarding the deduction under section 36(1)(vii), which was duly replied to by the assessee and the issue was considered while passing the assessment order, the High Court held that there was no failure on the part of the assessee to fully and truly disclose all material facts necessary for assessment and, therefore, the reassessment proceedings were quashed and set aside. (AY. 2014-15)

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