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TMI Blog2016 (5) TMI 1626X X X X Extracts X X X X X X X X Extracts X X X X ..... upon the provisions made in the earlier assessment years - HELD THAT:- The petitioner provided information to the respondents by their communication dated 21st January, 2014. Some of the details sought for by the AO were not responded to by the assessee. Notwithstanding the above, the AO on examination of the record appears to have been satisfied with the claim of provision for warranty made by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Jasani for the Petitioner Mr. A. R. Malhotra a/w N. A. Kazi for the Respondent ORDER P. C. 1. Heard. Rule. 2. The Petition challenges the notice dated 31st March, 2015 issued under Section 148 of the Act seeking to reopen the assessment for A.Y. 2010-11. The reasons in support of the impugned notice as communicated to the petitioner is on the basis that the provision for warranty made by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mates to make provision for warranty and also details of actual payment towards a warranty provision made with details of the person as also details of the preceding three assessment years indicating the opening balance and closing balance for the provision for warranty in each of the assessment years. The petitioner provided information to the respondents by their communication dated 21st January ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... opinion. 4. Mr. Malhotra, the learned counsel for the Revenue placed reliance upon the decision of this Court in Export Credit Guarantee Corporation of India v/s. Additional Commissioner of Income tax and others 350 ITR 651 to submit that where an Assessing Officer has overlooked or ignored in his assessment order the issue which arose for consideration during the assessment proceedings, it cann ..... X X X X Extracts X X X X X X X X Extracts X X X X
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