9911796707
TMI Blog2021 (12) TMI 1409X X X X Extracts X X X X X X X X Extracts X X X X ..... period of four years and the reasons recorded do not, in any manner, say that there was anything that had been done on the part of the petitioner assessee which has led to the income escaping the assessment. In absence of failure disclosed fully and truly all material facts, any reopening beyond a period of four years from the end of the assessment year 2014-15 is unsustainable. There is no whis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Income-Tax Act dated 31.03.2021 directing the petitioner to furnish the return of income for the assessment year 2014-15 on the ground that the assumption of jurisdiction itself is bad in law. 2. The petitioner is a foreign company having project office in India as per the approval of the Reserve Bank of India which is engaged in the business of extraction of crude petroleum and natural gas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income-Tax Act, names, PAN and addresses of the parties to whom the payments were made. The petitioner made payment of Rs.65,00,000/- to Shri Arvindo Institute of Applied Scientific Research as contribution towards expenditure of Thalassemia project of the trust and against the said donation assessee has claimed weighted deduction under Section 35(i)(ii) of the IT Act amounting to Rs. 1,13,75, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er relief deemed just and proper be granted in the interest of justice; (e) to provide for the cost of this petition. 3. We have heard learned advocate Mr. B.S.Soparkar appearing for the petitioner who has extensively taken us through the law and according to him, this is purely a question of law which arises for consideration as the reopening is beyond a period of four years and the r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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