Where assessee-corporate debtor was undergoing CIRP and NCLT had approved resolution plan on 26-4-2024, and tax allegedly escaping assessment for AY 2020-21 pertained to a period prior to approval of resolution plan but no claim relating to said assessment year had been filed by Revenue before NCLT, whereas claims relating to AYs 2018-19 and 2019-20 had been submitted, reassessment proceedings initiated for AY 2020-21, which did not form part of approved resolution plan, were to be quashed. (AY. 2020-21)
V Hotels Ltd. v. DCIT [2025] 177 taxmann.com 507 (Bom) (HC)
S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Approved resolution plan under IBC-Reassessment proceedings initiated for AY 2020-21, which did not form part of the approved resolution plan, were to be quashed.[S. 148, 148A(b), 148A(d), The Insolvency and Bankruptcy Code, 2016, S.31, 238, Art. 226]
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