Allowing the petition for the assessment years, 1996-19997 and 1997-98 the Court held that reassessment based on documents accompanying return of income and no new material discovered. Reassessment is held to be bad in law. As regards reassessment for the assessment years 2000-01 and 2015-16 the reassessment notices were issued based on discrepancies noted in value of land and doubtful debts in the statement of the computation of income and financials within period of four years. Reassessment is held to be valid. (AY. 1996-97, 1997-98, 2000-01, 2015-16)
Indian Syntans Investments (P.) Ltd. v. ACIT (2021) 279 Taxman 292 (Mad.)(HC)
S. 147 : Reassessment-After the expiry of four years-Income from lease rental-Reassessment based on documents accompanying return of income-No new material discovered-Reassessment is bad in law-With in four years-Reassessment based on discrepancies noted in value of land and doubtful debts in the statement of the computation of income and financials-Reassessment is held to be valid. [S. 36(1)(viia), 69A, 148, Art. 226]