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HC ruled that reassessment notice under Section 148 was invalid. The AO's reasons for reopening assessment lacked substantive evidence that escaped income was represented by an asset. The expenditure of Rs. 9.14 crores under 'wages and salaries', which included Rs. 6.29 crores for prior years, was transparently disclosed in financial statements. Since the conditions under Section 149(1)(b) were not satisfied, no reassessment notice could be issued after the limitation period of three years from the end of AY 2013-14. The petitioner, a joint venture between two public sector undertakings, had legitimate accounting practices for seconded employees' salary revisions. Consequently, the reassessment proceedings were set aside in favor of the assessee.
HC ruled that reassessment notice under Section 148 was invalid. The AO's reasons for reopening assessment lacked substantive evidence that escaped income was represented by an asset. The expenditure of Rs. 9.14 crores under 'wages and salaries', which included Rs. 6.29 crores for prior years, was transparently disclosed in financial statements. Since the conditions under Section 149(1)(b) were not satisfied, no reassessment notice could be issued after the limitation period of three years from the end of AY 2013-14. The petitioner, a joint venture between two public sector undertakings, had legitimate accounting practices for seconded employees' salary revisions. Consequently, the reassessment proceedings were set aside in favor of the assessee.
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