2016 (4) TMI 218

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....ent : Mr. R. Vijayaraghavan for M/s.Subbaraya Iyer JUDGMENT Both these appeals, filed by the Revenue under Section 260A of the Income Tax Act, were admitted on 10.10.2007 on the following substantial question of law: "Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in holding that the reopening of the assessment made by the Ass....

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.... an amount of Rs. 1,56,58,618/- has been claimed as exempt on the ground that the same represented bill discounting charges for the assessment year 1996-97. Similarly, it was also noticed that the assessee had claimed an amount of Rs. 1,05,20,866/- as exempt on the ground that the same represented bill discounting charges, for the assessment year 1997-98. 5. Therefore, the assessments were soug....

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....of all facts. 7. The nature of the omission on the part of the assessee was indicated in the notice for reopening the assessment as an omission to indicate the nature of the discounting charges. The amount, in respect of which, the assessee claimed exemption, related to discount on treasure bills. The Department claimed that under Section 2(7) of the Interest Tax Act, discounting charges alone ....

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....d a return under Section 7 or upon whom a notice has been served under Sub-Section (2) of Section 7 (whether a return has been furnished or not) a notice requiring him on a date thereon to be specified, to produce or cause to be produced such accounts or documents or evidence as the Assessing Officer may require for the purposes of this Act and may, from time to time, serve further notices requiri....