In the course of assessment proccedings questions relating to investments of assessee, income earned from it and disallowance of expenditure under section 14A were raised and replied to by assessee and thereafter, assessment order under section 143(3) was passed. Against the reassessment notice and order disposing the objection writ was filed. Allowing the petition the Court held that in absence of any circumstances about non-disclosure of true and full material on part of assesseee, reassement notice and order disposing the objection was quashed. (AY. 20014-15)
Sandesh Procon (P.) Ltd. v. ACIT (2023) 459 ITR 453 / 294 Taxman 52 (Guj.)(HC)
S. 147 : Reassessment-After the expiry of four years-No failure to disclose true and full material-Question was raised and reply was filed-Reassessment notice and order disposing the objection was quashed. [S. 14A, 142(1), 143(3), 148, Art. 226]