NLC India Ltd. v. ACIT (2022) 449 ITR 367 (Mad.)(HC)

S. 147 : Reassessment-After the expiry of four years-Employee benefit expenses-The successor officer had not come into possession of any other information to indicate escapement of income but merely relied upon the methodology adopted by the assessee to apprehend escapement of tax-Reassessment notice and order disposing the objection was quashed. [S. 148, Art. 226]

Allowing the petition the Court held that there was no other material that had come to the  notice post original assessment prompting  to take an alternate view. The successor officer had not come into possession of any other information to indicate escapement of income but merely relied upon the methodology adopted by the assessee to apprehend escapement of tax. Accordingly the notices for the assessment years 2014-15 and 2015-16 were quashed held to be not valid.(AY.2013-14 to 2015-16)