2025 (4) TMI 1461

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.... In this case, an order under Section 143 (3) of the Act was passed on 07 March 2013, assessing income of Rs. 83,78,100/-. Thereafter the impugned notice under Section 148 dated 24 March 2015 was issued within period of 4 years from the end of the relevant assessment year to reopen the case. 4. The reason as recorded for reopening the case reads as under:- Please refer to our letter dated 24th March 2015 requesting this office to provide the reasons recorded for re-opening the assessment u/s.147 of the Income Tax Act, 1961 in your case for A.Y.2010-11. 2. As requested, the reasons recorded for issuing notice u/s.148 of the 1.T.Act, 1961 are reproduced below: "1. The assessee filed the return of income for A.Y. ....

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....10-11 is being reopened on protective basis to safeguard the intrest of revnue by issue os notice u/s 148 of the Income Tax Act, 1961." (emphasis supplied) 5. In the reasons recorded, it is alleged that the Petitioner assessee has received cash to the tune of Rs. 1,85,66,920/- for assessment year 2010-11 based on the findings recorded in the assessment order for assessment year 2011-12. The assessment for assessment year 2011-12 was completed on 27 March 2014 and the said amount Rs. 1,85,66,920/- pertaining to assessment year 2010-11 was added in the assessment for assessment year 2011-12. In the reasons recorded, the officer has stated that the assessment for assessment year 2010-11 is being reopened on protective basis to safeguards th....