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2018 (12) TMI 1594 - HC - Income TaxReopening of assessment - addition of expenditure including technical assistance fee paid to AVL List GMBH, Austria - reasons to believe - Held that:- The assessee has given written explanation. Therefore the Commissioner (Appeals) held that it is a clear case of change of opinion and the correctness of this was tested by the Tribunal and the Tribunal noted that the required breakup details were furnished even at the time of original assessment and therefore, no new information available with the Assessing Officer nor any information was omitted by the assessee to be given to the Assessing Officer. Further, on the merits of the matter also, the Tribunal found that the decision of the Hon'ble Supreme Court in the case of Rotork Control Ltd. vs. CIT [2009 (5) TMI 16 - SUPREME COURT OF INDIA ] was applied. Thus, we find that there is no error in the order passed by the Tribunal. Accordingly, the appeal fails and dismissed. - Decided against revenue.
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