Suresh Chand Gupta v. PCIT (2020) 273 Taxman 66/ ( 2021 ) 438 ITR 657 (All.)(HC)

S. 147 : Reassessment-Audit objection-Income from other sources-Profit worked out profit on basis of contract/sub-contract income but failed to add interest income shown in books as other income-Reassessment is held to be valid. [S. 56, 148]

Assessing Officer worked out profit on basis of contract and sub-contract income. On account of oversight/mistake, he failed to add interest income shown in books as other income.  Subsequently, audit objections were raised by audit party Assessing officer issued notice under section 147 of the Act. Tribunal up held the reassessment order passed by the Assessing Officer.  Dismissing the petition the Court held that since in Profit and Loss Account, assessee himself had shown interest on FDRs as ‘other income’, question of double addition would not arise on reassessment. Reassessment is held to be proper.