2016 (5) TMI 1626

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..... spondent 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 petitioner was not made on a scientific basis and reliance was placed u .....

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..... 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, 2014. Some of the details sought for by the Assessing Officer were not respon .....

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..... n 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 cannot be deemed that the Assessing Officer has accepted what has been overlooked or ig .....

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