Sanjivani Non-Ferrous Trading (P) Ltd .v. ITO (2019) 308 CTR 532 / 177 DTR 276 (Delhi)(HC)

S. 147 : Reassessment-After the expiry of four years–Survey— Materials clearly showed that the sales declared were to be suspected—Re-opening was sustainable. [S. 133A, 148]

Dismissing the Writ of Assessee, it was held that the AO was of the opinion that the issue of profitability which required re-examination was pursuant to the survey conducted subsequently (not because of a second opinion or review) and which clearly showed that the sales declared were suspect, to say the least; hence reopening was sustainable.  (WP Nos. 11736, 12546 of 2018 dt 09-04-2019) (AY. 2011-12, 2012-13)