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2014 (2) TMI 24 - DELHI HIGH COURTValidity of re-assessment notice - recording of reason to believe - Excess exemption under section 10A - Held that:- CIT(A) has observed that there was no connection between the arbitration award and the receipt/payment - The reasons to believe were recorded on March 28, 2012, which is after the order passed by the Commissioner (Appeals) on March 15, 2011. Questions do arise about the genuineness of the said receipt as the company making the payment was a related party incorporated in the USA. However, on these issues, the reasons to believe are silent and there is no mention thereof or allegation in the grounds recorded by the Assessing Officer. Reassessment notice quashed - Decided in favor of assessee.
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