Renault Nissan Automotive India Pvt. Ltd. v. NEAC (2022) 446 ITR 555 / 220 DTR 405/(2023) 335 CTR 462(Mad.)(HC)

S. 147 : Reassessment-After the expiry of four years-Notice-Order of reassessment without considering objections-Not valid. [S. 148, Art. 226]

Held that when this reason was specifically objected to, that should have been also dealt with by giving reasons as to why the objection raised by the assessee against the limitation, i.e., beyond four years up to six years had to be rejected. In the absence of any such reasons stated in the rejection order dated January 3, 2022 on the specific objection raised in this regard by the assessee, even the rejection order was not justifiable as it was not in the expected line within the meaning of the provisions of law as well as the decision made by the law courts. (AY. 2014-15)