Reassessment Quashed: Beyond 4 Years Void Without New Material on AE Payments

Mphasis Limited Vs JCIT (Karnataka High Court) No Reopening on Change of Opinion: HC Upholds Full Disclosure Shield (Section 147 Proviso); Beyond Limitation: HC Quashes Second Section 148 Notice for Lack of Jurisdiction; Karnataka HC Quashes Re-assessment Beyond 4 Years — No Failure to Disclose Material Facts Mphasis Ltd, engaged in IT services & software development, challenged reopening of its A.Y. 2012-13 assessment initiated u/s 147 r/w 148, contending it was barred by limitation & without jurisdiction. The Company’s original assessment had been completed u/s 143(3) after deta...