Allowing the petition the Court held that since material facts relating to deduction towards sub-contract charges was a part of record, it could not be stated that there was failure of disclosure of material facts fully and truly, notice and order disposing the objection is set aside. (AY. 2009-10)
Infosys Ltd. v. ACIT (2024) 297 Taxman 101 (Karn.) (HC)
S. 147 : Reassessment-After the expiry of four years-Payment to sub-contract charges-No failure to disclose material facts-Reassessment notice and order disposing the objection is set aside.[S. 37(1), 143(3), 148, Art.226]