Principle of consistency applicable to determine whether for 148 income has escaped assessment or not

In the case of AVTEC Limited Vs. DCIT, Delhi High Court has held that- 1. Assessee is under no obligation to file the same document during assessment in each AY. The AO is to look at the litigation history of the assessee himself and cannot expect the assessee to inform him. 2. principle of consistency is applicable to determine whether for 148 income has escaped assessment or not. ————————- In the present case, the Court finds that the reasons for reopening the assessment for AYs 2008- 09 and 2009- 10 proceeded on the basis that the Assesse had...