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TMI Blog2017 (1) TMI 1750X X X X Extracts X X X X X X X X Extracts X X X X ..... (Appeals) - 1, Coimbatore, dated 26.08.2016 and pertains to assessment year 2007-08. 2. Shri R. Durai Pandian, the Ld. Departmental Representative, submitted that the assessee amortized a portion of project development expenditure and the balance amount was claimed as deferred revenue expenditure. This was noticed by the Assessing Officer after completion of original assessment. Therefore, the A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me. The Assessing Officer rightly reopened the assessment and disallowed the so-called expenditure of Rs. 2,65,78,000/-. 3. No one appeared for the assessee inspite of receipt of notice issued by RPAD. Therefore, we dispose of the appeal on merit after hearing the Ld. Departmental Representative. 4. From the orders of the lower authorities it appears that the assessee filed the return of income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... after expiry of a period of four years from the end of the relevant assessment year. In this case, the four years period from the end of the relevant assessment year expired on 31.03.2012. However, the Assessing Officer issued notice under Section 148 of the Act only on 11.06.2013. Therefore, obviously, the assessment was reopened after expiry of four years from the end of the relevant assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s from the end of the relevant assessment year is outside the scope of Section 147 of the Act. In view of the above, this Tribunal do not find any reason to interfere with the order of the lower authority and accordingly the same is confirmed.
6. In the result, the appeal filed by the Revenue is dismissed.
Order pronounced on 31st January, 2017 at Chennai. X X X X Extracts X X X X X X X X Extracts X X X X
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