TaxTMI 
TaxTMI 
TaxTMI 
2016 (5) TMI 285
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....arch 21, 2014, passed by the Assessing Officer disposing the objections raised by the petitioner. 2. The assessment in respect of the petitioner's income was completed under section 143(3) on December 15, 2010. The Assessing Officer had made certain additions on account of section 40(a)(ia) (Rs. 1,55,94,534) under section 14A (Rs. 1,55,603) and on account of extra depreciation claimed on computer peripherals (Rs. 6,87,043). 3. The impugned notice under section 148 was, as mentioned above, issued on March 21, 2013, beyond four years from the end of the relevant assessment year. Consequently, the first proviso to section 147 of the said Act would come into play. The said proviso stipulates that no action shall be taken under section 147....
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....work-in-progress (CWIP) at Rs. 2,83,56,670 for the period under consideration. However, the interest capitalised against the same has been shown at nil. From the above, it is clear that the asses see should have been capitalised. The assessee, however, claimed the same as revenue expenses instead thereby making a wrong claim. It is pertinent here to mention that similar claim of the assessee regarding the interest expenses has been disallowed by the Assessing Officer amounting to Rs. 24,73,568 for the assessment year 2009-10. Hence, it is clear that the assessee failed to disclose the true particulars of its income on this issue and the same was not dwelled upon by the Assessing Officer during the original assessment proceedings and no fi....
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....e was not dwelt upon by the Assessing Officer during the original assessment proceedings and no findings were given on this issue by the Assessing Officer. In view of the above, I have reasons to believe that taxable income on the above mentioned issues to the tune of Rs. 3,46,28,674 has escaped assessment and I am satisfied that it is a fit case for issue of notice under section 148 of the Income-tax Act." To complete the narration of facts, we may point out that the petitioner had filed objections on August 22, 2013, and they were disposed of by the impugned order dated March 21, 2014. 5. From the purported reasons it appears that the Assessing Officer in the first instance had raised an issue as to whether the interest payments were ....