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2017 (12) TMI 250 - HC - Income TaxReopening of assessment - petitioner company is incorporated in the United Kingdom which is engaged in the business of providing services and facilities in connection with exploration and extraction and production of mineral oils - 'reason to believe' - Held that:- In the present case, the Assessment Officer while assessing the income of petitioner company, has ignored the transactions made by it with its Associate Enterprises. He has also overlooked whether Section 3CEB was to be referred to the TPO. It is thus, not the change of opinion but the reassessment has been ordered on the basis of the tangible material placed on record necessitating the reassessment. Sufficient reasons have been assigned for reopening of the assessment. The objections raised by the petitioner company have been specifically dealt with by the respondent no.1. Impugned order dated 12.12.2011 passed by the respondent no.1 is detailed and reasoned. - Decided in favour of assessee.
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