Allowing the petition against the reassessment notice and order disposing the objections, the court held that there was no failure to disclose material facts therefore proposed reassessment proceedings for disallowance of guarantee commission, interest on borrowed capital, disallowance of expenditure in respect of exempt income and difference between Form 26AS Statement and books of account of assessee was held to be change of opinion hence the order was quashed. (AY. 2011-12)
P C Snehal Engineers (P.) Ltd. v. ACIT (2023) 291 Taxman 547 (Guj.)(HC)
S. 147 : Reassessment-After the expiry of four years-Guarantee commission-Interest on borrowed capital-Disallowance of expenditure-Exempt income-Method of accounting-Income reconciliation as per Form 26AS-No failure to disclose material facts-Reassessment notice and order disposing the objection was quashed.[S. 14A, 36(1)(iii), 37(1), 145, Form. 26AS, Art. 226]