Dismissing the petition the Court held that ; ADIT found that assessee did not bifurcate receipts into outside India and inside India and had, thus, failed to tax entire receipts in India as business income at maximum marginal rate as per Income-tax Act. There was also failure in computing income from outside India at a low rate, therefore reassessment was held to be valid .
Invensys Process Systems (S) v. ADIT (2018) 252 Taxman 199 (Uttarakhand) (HC)
S.147: Reassessment- Failure in computing income from outside India at a low rate – Reassessment was held to be valid [ S. 44BB, 148 ]