Reassessment proceedings without any new tangible material is unsustainable in law

Framji Dinshaw Petit Parsee Sanatorium Vs ITO (Bombay High Court) Bombay High Court held that reassessment proceedings, in absence of any failure to disclose any material fact and without any new tangible material which was not available at the time of passing of the original assessment order, is unsustainable. Facts- The Petitioner is a Public Charitable Trust registered u/s. 12A of the Income Tax Act. Petitioner addressed a letter to the Assistant Director of Income-tax (Exemptions) I-(2) informing him that they would not be able to utilise 85% of the accumulated income for the year towards ...