S.P. Singla Construction (P) Ltd. v. Dy.CIT (2025) 233 TTJ 559 / 245 DTR 357 (Chd)(Trib)

S.147: Reassessment-After the expiry of four years-Sub-contractors-No failure to disclose material facts-Reassessment order is quashed. [S.148]

Held that the assessee has  filed complete details of the subcontractors to whom assessee made payments and also filed details of all the work done by the said subcontractors which were not doubted by the AO during the original assessment proceedings, notice issued by the AO under s. 148 after the expiry of four years from the end of the relevant assessment year on the basis of claim of bogus subcontract is not sustainable. (AY. 2012-13)

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