2019 (2) TMI 1580

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.... with Section 144C of the Act on 30.04.2014, with an addition of Rs. 31.13 crores. The impugned reassessment notice in this case was issued on 30.03.2017; subsequently, the Assessing Officer (AO) furnished the "reasons recorded for issuance of notice" to the assessee. Those reasons inter alia states as follows : "2. Subsequently, Audit was conducted in the case of M/s FIS Global Business Solutions India Pvt. Ltd. And the Audit party pointed out that the assessee during the assessment year 2010-11 has claimed deduction of Rs. 3,11,80,117/- on a/c of Forex Gain on Certegry (Interest Income) and the same was allowed to the assessee by the A.O. Forex Gain on interest income, being revenue in nature, is not an allowable deduction. The mista....

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....he assessee company has wrongly claimed and was allowed deduction of Rs. 3,11,80,117/- on a/c of Forex Gain on Certegry which is not an allowable expenses which has escaped assessment. 7. In view of the above noted fact, I have reasons to believe that the income of Rs. 3,11,80,117/- which was chargeable to tax has escaped assessment for the A.Y.2010-11 on account of failure on the part of assessee to disclose fully and truly all material facts necessary for the assessment of the A.Y.2010-11 and this is a fit case to issue notice u/s 148 for the A.Y.2010- 11." It is urged that the assesssee is doing no more than re-visiting the merits of the original scrutiny assessment which case especially barred from conducting afresh. Learned counsel ....