Where, after completion of the original assessment, the Assessing Officer received information that the assessee had received its own undisclosed funds as loans from entities situated in Cyprus and Mauritius, which funds were routed through various companies located in tax havens having a connection with the assessee and its directors, the High Court held that such information, which was not available during the original assessment proceedings, constituted tangible material for reopening the assessment; further, the circuitous movement of funds had not been disclosed during the original assessment and, therefore, the reassessment proceedings were upheld. (AY. 2009-10).
Macrotech Developers Ltd. v. DCIT [2025] 174 taxmann.com 56 /2026] 489 ITR 363 (Bom) (HC)
S. 147: Reassessment-After the expiry of four years-Tangible material-Information regarding undisclosed funds routed through tax-haven companies-Reopening valid.[S. 69A, Art. 226]
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