Second Re-Assessment Notice Issued against Johnson & Johnson is Rejected by ITAT

Johnson & Johnson Private Limited Vs Add. CIT (ITAT Mumbai) The issue under consideration is whether the re-opening of assessment u/s 147 of the Act is justified in law? ITAT state that, the CIT has granted permission to the Assessing Officer for initiating reassessment proceedings without properly examining reasons for reopening. The reassessment proceedings were initiated beyond period of four years and nowhere in the reasons it has been brought out that the assessee has failed to disclose fully and truly all material facts necessary for the assessment. The CIT has not recorded his satis...