Case Law Details
Ambarnuj Finance And Investment Pvt. Ltd Vs DCIT (Delhi High Court)
Delhi high court held that there was no new/ fresh material before AO to initiate reassessment proceedings, accordingly, mere change of opinion cannot form the basis for initiating reassessment proceedings
Facts- During scrutiny assessment, AO disallowed the write off the ‘bad debt’ and made an addition to income of Rs. 30,00,152/- raising demand of Rs. 5,53,839/-.
Being eligible, the assessee availed benefit of Direct Tax Vivad Se Vishwas Scheme (DTVSV). However, via e-mail it was informed to the assessee that there was a computation mistake and a special rate of tax in lieu of business income was payable on Rs. 30,00,152/-. Accordingly, there is a short fall of Rs. 4,09,386/-.
AO consequently passed the impugned rectification order in exercise of his jurisdiction u/s. 154 of the Act of 1961, modifying the original assessment demand and raising a fresh enhanced demand of Rs. 9,27,047/- along with the interest.
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