Valid reassessment information excludes demerger receipts already taxed by resulting company, defeating extended limitation for reassessment.
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....Valid information for reassessment must point to income that escaped tax, not receipts disclosed, accounted for and taxed by the resulting company following a corporate demerger. Transactions appearing under the demerged entity's PAN because tax was deducted in its name before demerger sanction do not, without more, establish escapement. The extended reassessment period applies only where books, documents or evidence reveal previously undisclosed income meeting the prescribed threshold; material requiring only correlation of already disclosed transactions is insufficient. On these grounds, reassessment for the relevant assessment year was set aside as unsupported by valid information and time-barred.....
TaxTMI