Pharmazell (India) (P) Ltd. v ACIT (2025) 345 CTR 486 / 251 DTR 144 (Mad)(HC) Editorial : Pharmazell (India) (P) Ltd. v. ACIT (2025) 345 CTR 478 / 251 DTR 135 / 173 taxmann.com 181 (Mad)(HC), affirmed.

S.147: Reassessment-After the expiry of four years-Deduction claimed twice-Reassessment is justified.[S.37(1), 148, Art. 226]

 

Dismissing the petition the Court held that  although materials were disclosed during the course of assessment, the prima facie fact reveals that the deduction was wrongly claimed twice in the primary material and contains incorrect particulars. There was no proper declaration of income in the return of income. The AO cannot be faulted while reopening the Assessment and overrule the objection of the assessee. Further, Explanation to s. 147 makes it clear mere filing of information is not sufficient. (AY. 2014-15)

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