CIT v. Arvind Remedies Ltd (

378 ITR 547High Court2015#4099 most cited

What is CIT v. Arvind Remedies Ltd ( authority for?

The Assessing Officer must record their satisfaction or belief that income chargeable to tax has escaped assessment for the reopening of assessment to be valid.

29

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

CIT v Arvind Remedies Ltd · 378 ITR 547 · Assessing Officer satisfaction · belief of escaped income · reassessment validity · Section 147 · Section 148 · Madras High Court

Sections most often in play

Section 133ASection 139Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 143(1)

Issues it is cited on

fresh tangible materialfirst proviso to section 147beyond four yearsmaterial facts necessary for assessmentshort term capital gainskelvinatormere change of opinionlive linkshort term capital gainchange of opiniontangible materialregular assessment

Judgments citing CIT v. Arvind Remedies Ltd (

M. NATESAN,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2765/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

R.EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2697/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

S. EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

ITA 2696/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14
Section 133A

…le on record at the time of original assessment and therefore the\nAO had rightly reopened the assessment. In this regard, we find the\nreliance placed by the assessee on the decision of the Hon'ble Madras\nHigh Court in the case of CIT v Arvind Remedies Ltd (378 ITR 547)\nto be of relevance, wherein it has been held as follows:\n\n\"In the light of the above, we hold that when the Assessing Officer had\nfailed to record anywhere his satisfaction or belief that the income\nchargeable to tax had escaped assessment on account of the failure of\nthe assessee to disclose truly and fully all material facts necessary f…

S. EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2695/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

K. PARAMASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2693/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

K. BASKAR,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2692/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

K. BASKAR,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2691/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

K. SADASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2690/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

P. NALLUSAMY,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2687/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

K. KATHIRVEL,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2686/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

P. KARUNANITHI,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2685/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2591/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2590/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

M. VELUSAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2587/CHNY/2024[2013-14]Status: DisposedITAT Chennai09 Apr 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

M. VELUSAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2586/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

S. ARAVIND,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

ITA 2584/CHNY/2024[2012-13]Status: DisposedITAT Chennai09 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

…eopened the assessment. In this regard, we find the reliance placed by the assessee on t reliance placed by the assessee on the decision of the Hon’ble Madras the Hon’ble Madras High Court in the case of High Court in the case of CIT v Arvind Remedies Ltd ( (378 ITR 547) to be of relevance, wherein it has been held as follows: wherein it has been held as follows: “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had “In the light of the above, we hold that when the Assessing Officer had failed to record anywhere failed to…

ECI ENGINEERING & CONSTRUCTION COMPANY LTD., HYD,HYDERABAD vs. ACIT, CIRCLE-2(2), HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 968/HYD/2016[2006-07]Status: DisposedITAT Hyderabad15 May 2023AY 2006-07

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

For Appellant: Shri K.C. DevdasFor Respondent: Shri K.P.R.R. Murthy
Section 143(1)Section 143(3)Section 148Section 40

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad Before Shri R.K. Panda, Accountant Member AND Shri Laliet Kumar, Judicial Member Assessment Year: 2006-07 The Asst. Commissioner of Vs. M/s. ECI Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. PAN : AAACE74411G (Appellant) (Respondent) ITA 968/Hyd/2016 Assessment Year 2006-07 M/s. ECI Engineering & Vs. The Asst. Commissioner of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. PAN : AAACE74411G (Appellant) (Respondent) Assessee by: Shri K.C. Devdas Rev…

DCIT, CIRCLE-17(1), HYD, HYDERABAD vs. ECI ENGINEERING & CONSTRUCTION CO. LTD., HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 930/HYD/2016[2006-07]Status: DisposedITAT Hyderabad15 May 2023AY 2006-07

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

For Appellant: Shri K.C. DevdasFor Respondent: Shri K.P.R.R. Murthy
Section 143(1)Section 143(3)Section 148Section 40

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad Before Shri R.K. Panda, Accountant Member AND Shri Laliet Kumar, Judicial Member Assessment Year: 2006-07 The Asst. Commissioner of Vs. M/s. ECI Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. PAN : AAACE74411G (Appellant) (Respondent) ITA 968/Hyd/2016 Assessment Year 2006-07 M/s. ECI Engineering & Vs. The Asst. Commissioner of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. PAN : AAACE74411G (Appellant) (Respondent) Assessee by: Shri K.C. Devdas Rev…

GMR AIR CARGO & AEROSPACE ENGINEERING LTD(SUCCESSOR TO GMR HYDERABAD AIR CARGO & LOGISTICS PVT LTD),SHAMSHABAD vs. INCOME TAX OFFICER, WARD-2(3) , HYDERABAD

In the result, the appeal filed by the assessee is allowed

ITA 183/HYD/2020[2008-09]Status: DisposedITAT Hyderabad14 Sept 2022AY 2008-09

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2008-09 Gmr Air Cargo & Vs. Ito,Ward-2(3) Aerospace Engineering Signature Towers Ltd.(Successor To Gmr Kondapur, Kothaguda Hyderabad Air Cargo & Opp. Botanical Gardens Logistics Pvt Ltd.) R.R.District Rajiv Gandhi International Hyderabad-500 084 Airport, Samshabad Hyderabad-500 409

For Appellant: Shri K.C.DevdasFor Respondent: Shri Kumar Aditya, Sr.AR
Section 143(1)Section 143(3)Section 147Section 148Section 37

…. Kohinoor Hatcheries (P.) 1 Ltd. v. Deputy Commissioner of Income-tax [2016] 76 taxmann.com 150 (AP.HC) vi. OHM Stock Brokers (P.) Ltd. v. 1 CIT (351 ITR 443) (bom.HC) vii. Runwal Realty (P.) Ltd.v.DCIT 1 (107 taxmann.com 284) (bom.HC) viii. Arvind Remedies (378 ITR 547) (Mad.HC) ix. Indian Bank(63 taxmann.com 145)(Mad HC) x. Godrej Agrovet Ltd. v. DCIT[2015] 56 taxmann.com 141(Bom.HC) xi. Paladiya Brothers & CO.v.ACIT[2015] 61 tamxann.com 26(Guj.) xii. NTPC Ltd. DCIT[2013] 32 taxmann.com 343 (Del.) xiii. Sita Wrold Travel (India) Ltd. v.CIT(274 ITR 186)(Del.HC) 15. Referring to the following decisions, he subm…

ITO, NON CORPORATE WARD -15(3), CHENNAI vs. SHRI RAMACHANDRA RAMAN, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the Cross Objection filed by the assessee is allowed

ITA 124/CHNY/2018[2009-10]Status: DisposedITAT Chennai08 Jun 2022AY 2009-10

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.124/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 & C.O. No. 58/Chny/2018 [In I.T.A. No.124/Chny/2018] The Income Tax Officer, Vs. Shri Ramachandra Raman, Non Corporate Ward 15(3), 21B, Deccan Parvathy, 2Nd Floor, Room No. 206, Wanaparthy Kannappa Nagar Extension, Block, 121, M.G. Road, Thiruvanmiyur, Chennai 41. Chennai – 600 034. [Pan: Aehpr6467D] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri Sajit Kumar, Jcit Assessee By : Shri T. Banusekar, C.A. सुनवाई की तारीख/ Date Of Hearing : 17.05.2022 घोषणा की तारीख /Date Of Pronouncement : 08.06.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Revenue & The Cross Objection Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 28.09.2017 Relevant To The Assessment Year 2009-10. 2. The Cross Objection Filed By The Assessee Is In Respect Of Reopening Of Assessment Under Section 147 Of The Income Tax Act

For Appellant: Shri T. Banusekar, C.AFor Respondent: Shri Sajit Kumar, JCIT
Section 143(1)Section 143(3)Section 147Section 148Section 3Section 54ESection 54F

…ssee to disclose fully and truly all material facts necessary for assessment and relied on the judgements of Hon’ble Jurisdictional High Court in the case of CIT v. Schwing Stetter India P. Ltd. 378 ITR 380 (Mad) and in the case of CIT v. Arvind Remedies Ltd. 378 ITR 547 (Mad). It was further submission that having completed the original assessment under section 143(3) of the Act by allowing exemption under sections 54EC and 54F of the Act, the reopening of assessment to disallow exemptions under section 54EC & 54F of the Act tantamount to review of the original assessment order, which is mere change of opinion a…

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