https://www.taxtmi.com/caselaws?id=366984 Reassessment under ss. 147/148 was challenged on the ground that the alleged undervaluation of share allotment under s. 56(2)(vii)(c)(ii) read with r. 11UA was erroneous and could not constitute "tangible material." The HC held that the dominant basis was nondisclosure of the taxing event (share allotment) and absence of any value declaration, which prevented the AO from examining the issue. For the assessee earlier assessed under s. 143(3), post-assessment TEP/investigation reports constituted tangible material under Kelvinator, warranting reopening; for the other assessees, prior processing under s. 143(1) was not an "assessment" under Zuari, permitting reopening. The writ petitions were dismissed. en-us Mon, 10 Sep 2018 00:00:00 +0530 Mon, 12 Jan 2026 13:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=366984 Reassessment under ss. 147/148 was challenged on the ground that the alleged undervaluation of share allotment under s. 56(2)(vii)(c)(ii) read with r. 11UA was erroneous and could not constitute "tangible material." The HC held that the dominant basis was nondisclosure of the taxing event (share allotment) and absence of any value declaration, which prevented the AO from examining the issue. For the assessee earlier assessed under s. 143(3), post-assessment TEP/investigation reports constituted tangible material under Kelvinator, warranting reopening; for the other assessees, prior processing under s. 143(1) was not an "assessment" under Zuari, permitting reopening. The writ petitions were dismissed. Case-Laws Income Tax Mon, 10 Sep 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=366984