2018 (2) TMI 1379

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....s: "In this case the return of income was filed on 29.09.2010 declaring total income at Rs. 48,74,33,250/. He return was duly processed under Sec.143(1) of the I.T. Act on 07.05.2011 assessing total income at Rs. 48,74,33,252/. The case was selected for scrutiny and assessment order u/s. 143(3) r.w.s. 153B(1)(b) of the Income tax Act as passed on 30.12.2011 assessing total income at Rs. 48,78,06,437/. It has been gathered that the Company owned a land which was purchased in the year 1995-56, at a cost of Rs. 4,22,259/which was converted into stockintrade. He fair value of land as on 01.04.1981 stood at Rs. 12,82,000/. On the said land company has constructed a commercial complex admeasuring 52759 Sq. ft., out of which 2641 sq. ft. ....

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....n was filed. 3. Appearing for the petitioner, learned counsel for the petitioner raised following contentions: I. The original assessment was framed after scrutiny. Impugned notice has been issued beyond a period of four years from the end of relevant assessment year. There was no failure on the part of the assessee to disclose truly and fully all material facts. There was no external material available with the Assessing Officer to form a belief that income chargeable to tax has escaped assessment. II. The Assessing Officer was acting at the behest of the audit party. Impugned notice has been issued only on the basis of audit objections. III. Even otherwise, the reasons lack validity. The petitioner's comp....