Claim Allowed in Original Assessment Cannot be Amenable to Provisions of Section 147/148

TCG Development India Private Limited Vs ITO (ITAT Delhi) The issue under consideration is whether the notice issued under section 147 for re-opening of assessment is justified in law? ITAT states that from the material available on record it is evident that during the course of original assessment proceedings, on the issue of allowability, the assessee had disclosed the information to the AO and thus it would appear that assessee had disclosed the primary facts at its disposal to the Assessing Officer for the purpose of assessment. In such circumstances, it cannot be said that assessee did no...