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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.
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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