Assessing Officer passed reassessment order on account of prior period items, receivables and advertisement expenses. On appeal, Commissioner(Appeals) upheld reopening of assessment on ground that factum of giving away 75 vehicles to its dealers as commission for achieving sales targets and incentives was not disclosed by assessee and same impedes requirement of true and full disclosure at time of original assessment. On appeal the Tribunal quashed the Reassessment proceedings. On appeal the High Court affirmed the order of the Tribunal on the ground that there is no failure to disclose material facts. Order of Tribunal is affirmed. No substantial question of law. (AY. 2002-03)
PCIT v. Samsung India Electronics (P.) Ltd. (2024) 300 Taxman 21 (Delhi)(HC)
S.147: Reassessment-After the expiry of four years-Unexplained expenditure-Prior period items and advertisement expenses-No new tangible material-Quashing of reassessment by the Tribunal is affirmed. [S.69C, 148, 260A]