https://www.taxtmi.com/caselaws?id=759590 The Delhi HC dismissed a petition challenging reopening of assessment u/s 147 for AY 2011-12. The petitioner argued that all material was already examined in AY 2010-11 assessment, making the reopening invalid. The court held that the AO had credible reasons to believe income escaped assessment, based on statements recorded during search proceedings revealing bogus billing arrangements through M/s JMD International. The court found that certain amounts received from M/s JMD International in FY 2010-11 were not taxed in AY 2011-12, and since no assessment was framed u/s 143(3) for AY 2011-12, the reopening was justified and not based on mere change of opinion. en-us Thu, 26 Sep 2024 00:00:00 +0530 Fri, 04 Oct 2024 08:19:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759590 The Delhi HC dismissed a petition challenging reopening of assessment u/s 147 for AY 2011-12. The petitioner argued that all material was already examined in AY 2010-11 assessment, making the reopening invalid. The court held that the AO had credible reasons to believe income escaped assessment, based on statements recorded during search proceedings revealing bogus billing arrangements through M/s JMD International. The court found that certain amounts received from M/s JMD International in FY 2010-11 were not taxed in AY 2011-12, and since no assessment was framed u/s 143(3) for AY 2011-12, the reopening was justified and not based on mere change of opinion. Case-Laws Income Tax Thu, 26 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759590