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2010 (2) TMI 269 - HC - Income TaxReassessment- The assessee was engaged inter alia in the business of providing audiovisual television software, films, event and other like activities. It also acted as an agent for foreign television companies for canvassing the sale of airtime for channels for which it received agency fees. For the assessment year 2004-05 the Assessing Officer allowed to the assessee a deduction on account of expenditure incurred towards advertisement, publicity and market research. On march 25, 2009 the Assessing Officer issued a notice u/s 148 proposing to reopen the assessment proceedings for assessment year 2004-05. The reason recorded by the Assessing officer were that during the course of assessment proceeding of the subsequent assessment year 205-06, the Assessing officer had made a specific addition under the head of advertisement, sale promotion, market research expenses, wherein an amount of Rs. 32.49 crores was added back to the income o the assessee. Held that- the Assessing Officer did so on the basis of fresh material which came before him in view of the notice dated Nov. 26, 2008 in pursuance of which the assessee filed a detailed representation elucidating the relevant particular of the business of the assessee. The Assessing Officer did have tangible material to reopen the assessment under section 147. The notice of reassessment was valid. Dismissed the petition.
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