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State Bank of India v. ACIT ( 2018) 172 DTR 401 /96 taxmann.com 77/ ( 2019) 411 ITR 664 (Bom)(HC),www.itatonline.org

S. 147 : Reassessment –With in four years-Disclosure in computation – The fact that the AO did not raise specific queries and is silent in the assessment order does not mean there is no application of mind – Reassessment is held to be bad in law .[ S.143(3),148 ]

Allowing the petition the Court held that ,computation  is the basic document for making the  S.. 143(3) assessment. If there is a disclosure in the computation, it leads to the prima facie necessary inference that there is application of mind by the AO. The fact that the AO did not raise specific queries & is silent in the assessment order does not mean there is no application of mind ITO v. Techspan ( 2018) 404 ITR 10(SC) followed.( WP271-2018 /) WP-278-2018 dt. 15.06.2018), ( AY. 2013- 14, 2014-15 )

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