S. 147 Reopening based on material placed before DRP considering the same as new material

In the present case, the Assessing Officer and the DRP had examined the issue of business restructuring. Even the fact that receipts upto and including July 2007 were offered for taxation in the hands of the petitioner and thereafter, that is, from August, 2007 to 31.03.2008, the revenues were to be raised in the hands of the petitioner’s 100% subsidiary, namely, LIG, were clearly, noticed and recorded not only in the final assessment order, but also in the draft assessment order and the proceedings before the DRP. Therefore, we cannot agree with the learned counsel for the revenue that the ...