2017 (1) TMI 316

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..... e part of the petitioner to disclose fully and truly all material facts necessary for assessment. Moreover, the petitioner in its objections to the reasons recorded pointed out that this is a case of mere change of opinion, as this very issue was the subject matter of inquiry during regular assessment proceedings as is evident from the Annexure-II to the notice dated 29th July, 2011 issued under S .....

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..... ibit 'G' respectively. Re-verification dispensed with. Amendment to be carried out forthwith. 2. Heard. 3. Rule. 4. This petition challenges the notice dated 31st March, 2016 issued under Section 148 of the Income Tax Act, 1961 (the 'Act'). The impugned notice seeks to reopen the assessment for the Assessment Year 2009-10. Thus the impugned notice is beyond the period of f .....

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..... m during F.Y. 2008-09 relevant to A.Y. 2009-10. In view of the above, I have reason to believe that income chargeable to tax has escaped assessment to the tune of ₹ 15,08,35,353/- and it is fit case for re-opening the assessment under the provisions of Section 148. 5. As is evident from the above the reasons are bereft of any basis to come to the conclusion that the income charge .....

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