https://www.taxtmi.com/caselaws?id=384220 The Delhi HC upheld ITAT's decision dismissing Revenue's appeal on multiple grounds. Regarding reassessment under Section 147, the court held that since Revenue failed to challenge CIT(A)'s order quashing reassessment proceedings (which were based solely on revenue audit objections without tangible material constituting mere change of opinion), ITAT correctly refused to examine merits. This was not a technical approach but substantively justified given the invalid reassessment foundation. On income computation, the court confirmed that life insurance businesses must compute income under Section 44 read with First Schedule, which overrides other Act provisions through non-obstante clauses. The assessee was justified in filing revised computation as additional ground before CIT(A). Regarding penalty under Section 271(1)(c), ITAT correctly followed established precedent requiring penalty notices to specify whether initiated for concealment or inaccurate particulars. The defective notice rendered penalty proceedings invalid. No substantial questions of law arose on any issue. en-us Fri, 02 Aug 2019 00:00:00 +0530 Mon, 21 Jul 2025 10:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=384220 The Delhi HC upheld ITAT's decision dismissing Revenue's appeal on multiple grounds. Regarding reassessment under Section 147, the court held that since Revenue failed to challenge CIT(A)'s order quashing reassessment proceedings (which were based solely on revenue audit objections without tangible material constituting mere change of opinion), ITAT correctly refused to examine merits. This was not a technical approach but substantively justified given the invalid reassessment foundation. On income computation, the court confirmed that life insurance businesses must compute income under Section 44 read with First Schedule, which overrides other Act provisions through non-obstante clauses. The assessee was justified in filing revised computation as additional ground before CIT(A). Regarding penalty under Section 271(1)(c), ITAT correctly followed established precedent requiring penalty notices to specify whether initiated for concealment or inaccurate particulars. The defective notice rendered penalty proceedings invalid. No substantial questions of law arose on any issue. Case-Laws Income Tax Fri, 02 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=384220