Asian Paints Ltd. v. DCIT

308 ITR 195High Court2009#551 most cited

What is Asian Paints Ltd. v. DCIT authority for?

An Assessing Officer cannot issue a notice under Section 148 to reopen an assessment when all material facts were already before the AO during the original assessment, even if the AO failed to apply their mind at that time. Such an action constitutes an impermissible review of a concluded assessment rather than a reassessment based on fresh tangible material.

175

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.

Also referred to as

Asian Paints Ltd. v. DCIT · Section 148 · Section 147 · reopening of assessment · mere change of opinion · full and true disclosure · tangible material · escapement of income · concluded assessment · original assessment facts

Issues it is cited on

Judgments citing Asian Paints Ltd. v. DCIT