Nielsen (India) P. Ltd. v. Dy. CIT (2020) 187 DTR 451 (Bom) (HC)

S. 147 : Reassessment –Failure to deduct tax at source- No failure to disclose material facts – Reassessment is bad ib law .[ S.40(a)(ia), 148 Art , 226 ]

Allowing the petition the Court held that  all material facts, there was scrutiny of the petitioner’s expenditure. After raising queries and eliciting response from the petitioner, the Assessing Officer had passed the order of assessment making limited disallowance. On both these grounds i.e non failure to disclose true and full material facts and change of opinion, the impugned notice must be quashed .(AY. 2011-12)