Tax Reassessment Upheld: Subsidiary's Funds Deemed Unaccounted Income Under Section 68 Despite Prior Tribunal Ruling

The HC upheld reassessment proceedings initiated by the AO against the petitioner based on funds received by NNPLC (petitioner's wholly-owned subsidiary). The AO relied on DRP's view that NNPLC was established without reasonable business purpose and its funds constituted unaccounted income of the petitioner under Section 68. Despite a Special Bench of the Tribunal previously concluding that petitioner had not extended corporate guarantee to NNPLC, the HC determined sufficient material existed to justify reassessment. The court rejected petitioner's argument that DRP's order was misconstrued, noting this contention was not raised in earlier litigation before HC or SC. The SC had previously affirmed the AO's reliance on DRP's order was justified. Challenge to reassessment action dismissed. .....

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