Bombay HC: No Disclosure Failure, No Reopening After 4 Years

Stock Holding Corporation of India Ltd. Vs ACIT (Bombay High Court) Reassessment Without Alleging Disclosure Failure: Bombay HC Denies Revenue a Second Bite at the Cherry Facts- The Petitioner, Stock Holding Corporation of India Ltd., challenged the reopening of its assessment for AY 2013-14 by a notice issued under Section 148 of the Income Tax Act, 1961, dated 31st March 2021. A scrutiny assessment under Section 143(3) had already been carried out for AY 2013-14, with an order passed on 7th March 2016. The impugned notice for reassessment was issued after a period of 4 years from the end of...