Raajratna Stockholdings Pvt. Ltd. v. ACIT (2025) 476 ITR 228 /170 taxmann.com 473 (Guj)(HC)

S.147: Reassessment-After the expiry of four years-No failure to disclose all material facts-Borrowed satisfaction-Notice and order disposing the objection was quashed. [S. 143(3), 148, Art. 226]

Allowing the petition the Court held that the Assessing Officer could not have assumed the jurisdiction merely and solely relying upon the information made available on the insight portal without forming any independent opinion on the basis of the material on record. The notice issued under section 148 for the assessment year 2013-2014 was quashed and set aside.(AY. 2013-14)

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