Khed Economic Infrastructure P. Ltd. v. Dy. CIT (2023)107 ITR 83 (SN)(Pune) (Trib)

S.147: Reassessment-After the expiry of four years-With in four years-Raised specific query in the original assessment proceedings-No new tangible material-Reassessment is bad in law.[S. 143(3 148]

Held that the assessee raising specific queries regarding the interest income in question followed by the assessee’s clarifications. The assessee had placed on record its balance-sheets, tax audit reports and audited annual accounts, throwing sufficient light on the details of interest income. Therefore, for the assessment years 2011-12 and 2012-13 the reopening of the assessments did not satisfy the test of the Assessing Officer’s having recorded any specific satisfaction based on fresh tangible material that the assessee had not disclosed “fully” and “truly” all the relevant particulars in the course of regular assessments.(AY.2011-12 to 2013-14)