Allowing the petition the Court held that the Assessing Officer had not been able to crystallize, what according to him was the exact amount of income which was chargeable to tax which had escaped assessment under section 147. Therefore, an opportunity was to be given to the assessee to file objections to the notices issued under the unamended provisions of section 148 and the Assessing Officer was to consider the objections and accordingly pass a speaking order. (AY.2015-16 to 2017-18)
Swarovski India Pvt. Ltd. v CIT (2023)455 ITR 656 (Delhi)(HC)
S. 147 : Reassessment-Notice-Not specifying exact amount of income chargeable to tax which had escaped assessment-Reassessment order and consequential order and notices are set aside-Opportunity must be given before passing the order. [S. 144, 147, 148, 156, 226, 271(1)(b), 271(1)(c), 271F, Art. 226]