Case Law Details
Carborundum Universal Limited Vs ACIT (ITAT Chennai)
Introduction: Carborundum Universal Limited vs ACIT (ITAT Chennai) is a landmark case that highlights a significant legal principle within the Indian Income Tax Act of 1961. This case revolves around the reopening of assessment and its viability when the issue is already the subject matter of appeal. The case gives insight into the application of the provisions of section 147 and section 14A of the Act, and it provides clarity on the limitations regarding the reopening of assessments.
Analysis:
1. Background and Appeal Grounds: The case emerges from the reassessment process undertaken by the Assessing Officer (AO) for the assessment year 2015-16. The assessee argued that the reopening was contrary to law, and the Income Tax Appellate Tribunal (ITAT) Chennai agreed with the assessee on several grounds.
2. Reopening of Assessment: The AO reopened the assessment to examine the disallowance under section 14A r.w.r. 8D of I.T. Rules, 1962. However, the issue had already been a subject matter on appeal, thus raising legal questions.
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