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of <h1>Special leave petitions dismissed against reopening assessment under s.147 where full facts on advertisement and sales-promotion were placed before AO</h1> <h3>THE ASSISTANT COMMISSIONER OF INCOME TAX & ORS. Versus ASIAN PAINTS LIMITED</h3> SC dismissed special leave petitions challenging reopening of assessment under s.147 where HC had found that full material facts concerning advertisement ... Reopening of assessment u/s 147 - notice issued after the expiry of four years - disallowances reflected in the advertisement and sales promotion expenses - HELD THAT:- As the income tax returns were taken up for regular assessment and thereafter, order u/s 143(3) of the Act was passed. There is a categorical finding by the High Court that full material facts with regard to the expenditure in question were placed by the assessee – Asian Paints Ltd. before the AO during the course of the regular assessment proceedings. No merit in the present special leave petitions and the same are dismissed. The Supreme Court dismissed the special leave petitions regarding the notice issued under Section 148 of the Income Tax Act, 1961 after the expiry of four years from the end of the relevant assessment year. The Court found that full material facts regarding the expenditure were presented by the assessee, Asian Paints Ltd., during the regular assessment proceedings.
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