2017 (1) TMI 1750

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.... of the Commissioner of Income Tax (Appeals) - 1, Coimbatore, dated 26.08.2016 and pertains to assessment year 2007-08. 2. Shri R. Durai Pandian, the Ld. Departmental Representative, submitted that the assessee amortized a portion of project development expenditure and the balance amount was claimed as deferred revenue expenditure. This was noticed by the Assessing Officer after completion of o....

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....e allowed while computing total income. The Assessing Officer rightly reopened the assessment and disallowed the so-called expenditure of Rs. 2,65,78,000/-. 3. No one appeared for the assessee inspite of receipt of notice issued by RPAD. Therefore, we dispose of the appeal on merit after hearing the Ld. Departmental Representative. 4. From the orders of the lower authorities it appears that ....

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....as negligence on the part of the assessee, after expiry of a period of four years from the end of the relevant assessment year. In this case, the four years period from the end of the relevant assessment year expired on 31.03.2012. However, the Assessing Officer issued notice under Section 148 of the Act only on 11.06.2013. Therefore, obviously, the assessment was reopened after expiry of four yea....