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        Case ID :
        Income Tax

        HC quashed reassessment notice under s.147/148 of Income Tax Act...

        Income Tax Reassessment Notice Under Section 147/148 Quashed Due To Prior Full Disclosure Of Interest-Free Group Loans

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                HC quashed reassessment notice under s.147/148 of Income Tax Act concerning interest-free loans to related entities and interest claims on borrowed funds. The assessee had made complete disclosure in original returns filed on 29.09.2013 including balance sheet and P&L statements. RTI documents revealed AO had formed opinion on interest-free group loans during original assessment concluded on 29.06.2015. Court found no failure by assessee to disclose material facts necessary for assessment. The subsequent reopening was unwarranted as AO had previously justified original assessment conclusions in response to audit objections. Notice dated 28.03.2021 and speaking order dated 29.07.2021 were held unsustainable.
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