The assessment of the petitioner was completed u/s 143(3) of the Act. allowing the deduction u/s 8IB and 80IC of the Act. The reassessment notice was issued to disallow the claim allowed in the original assessment proceedings. On writ the Court held that the Assessing Office was acting solely on basis of information and material already on record in original assessment, hence reopening notice issued beyond period of four years was unjustified and quashed. (AY. 2011-12)
Marico Ltd v. ACIT (2021) 133 taxmann.com 121 (Bom.)(HC) Editorial : SLP of revenue is dismissed; ACIT v. Marico Ltd. (2022) 284 Taxman 365 (SC)
S. 147 : Reassessment-After the expiry of four years-Alleged excess deduction-Basis of information and material already on record-Re assessment notice was quashed. [S. 80IB, 80IC, Art. 226]