PCIT v. Farmson Pharmaceuticals Gujarat (P.) Ltd. (2024) 164 Taxmann.com 378 / (2025) 473 ITR 639 (Guj)(HC)

S. 147 : Reassessment-After the expiry of four years-Additional depreciation-No failure to disclose material facts-Order of Tribunal quashing the reassessment order is affirmed. [S.32, 148, 260A]

Dismissing the appeal of the Revenue the Court held that reopening of assessment after four years, based solely on details from profit and loss account filed by assessee, without new tangible material or failure by assessee to disclose material facts was invalid when original assessment was completed under section 143(3) after full scrutiny. Order of Tribunal is affirmed. (AY.2008-09)

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