Om Synergy Spacelink (P.) Ltd. v. NFAC (2025) 302 Taxman 201 (Guj.)(HC)

S.147: Reassessment-After the expiry of four years-Unexplained investment-Borrowed satisfaction-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed. [S. 69, 142(1), 148, Art.226]

Allowing the petition the Court held that  the  notice was issued on basis of borrowed satisfaction without having any live nexus with facts on record when transactions in question were duly reflected in books of account in form of audited balance-sheet as well as in reply to notice under section 142(1). On the facts since there was no failure on part of assessee to disclose truly and fully all material facts during regular assessment notice and order disposing the objection is quashed. (AY. 2013-14)

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