Allowing the petition the Court held that, the from the reasons recorded it is observed that the Assessing Officer had relied upon facts and figures available from accounts and there was no tangible material on record to conclude that income had escaped assessment. The Assessing Officer had acted in excess of limit of his jurisdiction. Accordingly the notice and order passed is quashed. (AY. 2015-16)
Nuclear Power Corporation of India Ltd. v. Dy. CIT (2023) 294 Taxman 365 (Bom.)(HC)
S. 147 : Reassessment-After the expiry of four years-Infrastructure development-Change of opinion-Pendency of appeal before CIT(A)-No failure to disclose material facts-Reassessment notice and order disposing the objection was quashed.[S. 80IA, 148,246A, Art. 226]