Dismissing the petitions the Court held that there existed material to infer that income had escaped assessment . On the issue under consideration were not filed during the course of the assessment proceeding or were not considered during the assessment. Issue of notice is held to be valid .
Precision Engineering v. ACIT(2020)427 ITR 198 /196 DTR 371 (Chhattisgarh) (HC) Aaditya Construction v. PCIT (2020)427 ITR 198/196 DTR 371 (Chhattisgarh) (HC) Editorial : Affirmed by division bench , Precision Engineering v . ACIT ( 2021 ) 319 CTR 217 / 198 DTR 311 (Chhattishgarh )(HC) Aaditya Construction v. PCIT ( 2021 ) 319 CTR 217 (Chhattishgarh )(HC)
S. 147 : Reassessment –With in four years- Existence of material- Reassessment notice is held to be valid [ S.148 Art .226 ]