TaxTMI 
TaxTMI 
2013 (1) TMI 153
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....ores. The return was accompanied by the computation sheet, profit and loss account and balance sheet as on 31.3.2003. The assessment was completed on 24.03.2006 under section 143(3) of the Income Tax Act at a loss of Rs.11.32 crores. An appeal against the assessment is stated to be pending. On 31.8.2007, the respondent issued a notice under Section 148 reopening the assessment on the ground that income chargeable to tax had escaped assessment. Pursuant to the said notice, a reassessment was completed under Section 147/143(3) on 23.12.2008 in which an addition of Rs.2.45 crores was made, which is also to be challenged in appeal before the Income Tax Appellate Tribunal. 2. On 26.03.2010 another notice under Section 148 was issued reopening....
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....cessarily amount to disclosure with the meaning of the foregoing proviso. In view of above facts, I have reason to believe that income chargeable to tax amounting to Rs.2,52,14,220/- has escaped assessment in the case and the same is to be brought to tax under section 147/148 of the I.T.Act Sanction for issue of notice u/s 148 as prescribed u/s 151 to reassess such income and also any other income chargeable to tax which has escaped assessment and which comes to the notice subsequently during the course of assessment proceedings may kindly be accorded. (Signature of Officer) Sd/- Name B. Srinivas Kumar Designation DCIT Circle-15(1) Dated: 11.03.2010" The petitioner's objections to the effect that the reassessment was wi....
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....er company. The transfer was to take effect from 01.10.2001 subject to approval from financial institutions which came only after 31.12.2002. Till that time, both the income and the expenses relating to the paper board division for the period from 1.10.2001 to 31.12.2002, covering parts of two different accounting years, were accounted for in the books of the petitioner. For the period from 1.10.2001 to 31.3.2002 which was relevant to the assessment year 2002-03, there was an excess of expenses over the income with respect to the paper division and such excess amounted to Rs.2,52,14,220/-. This was accounted for in the petitioner's books of account for the year ended 31.03.2002. Accordingly, the aforesaid loss relating to the paper board di....
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....ansferred to R T Paper Board Limited 25214220 25214220 Revised loss for filing I. Tax Return -3849780 Note : Detail of prior period income & expenditure transferred to R T PAPER BOARD LIMITED, a subsidiary Company, is attached. This annexure is as per TAR for the A.Y. 2003-04." The note appended to the revised return reads as under (relevant portion): "Consequent to restructuring, return is being revised as per under mentioned details. 1. In the return of A.Y. 2003-04 a sum of Rs.25214220/- has been shown as previous year income in the Balance Sheet. The necessary details of the same have been given in the Note No.B-2(e) of the Financial Statement. This amount pertains to the losses arising from operations o....
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....10.2001 to 31.03.2002 1.4.2002 to 31.12.2002 Amount Amount Income : Gross Turnover 297.45 0 Less : Excise duty 2.05 0 Net turn over 295.40 0.00 Service fee 1.06 0 Other income 11.01 0.13 Decrease in stocks -59.72 0 Total income (A) 247.75 0.13 Expenses : Raw material consumed 113.10 0.00 Administrative and other expenses. 261.28 229.87 Interest 25.67 143.79 Depreciation 99.84 149.95 Total expenditure (B) 499.89 523.61 Excess of expenditure over income transferred to R T Paper Board Ltd. -252.14 -523.48 In the computation of income for the year ended on 31.03.2003 i.e. for the assessment year 2003-04, the l....