Piyush Ambalal Gandhi.v. DCIT (2023) 457 Itr 411/ 291 Taxman 396 (Guj)(HC)

S. 147 : Reassessment-With in four years-Contribution to certain funds-Not claimed any relief-Reassessment notice and order disposing the objection was quashed.[80CCC(1), 148, Art. 226]

Allowing the petition, the High Court held that the facts relating to issue on the basis of which the reopening of the assessment was sought were earlier called for by the AO and all such information was furnished by the Assessee. Further, the Assessee having furnished details and clarified his stand with clear and convincing facts relating to the investment by him in the pension policy, source of funds applied and further pointing out that the deduction was not claimed in that regard under Section 80CCC(1) rendering the receipt of surrender value not liable to be offered to tax. Reassessment notice and order disposing the objection was quashed.  (AY. 2013-14)