Mere disclosure of a transaction during original assessment proceedings does not protect assessee from re-assessment

Mere disclosure of a transaction at the time of the original assessment proceedings does not protect the assessee from a re-assessment under section 147 if the assessing officer has information that indicates that the transaction is sham or bogus. In the present case, NDTV has alleged that the details of the corporate guarantee issued by NDTV to NNPLC regarding the Step Up Coupon Bonds was intimated to the Revenue during the original assessment proceeding. This argument of NDTV falls flat in light of the judicial decisions mentioned above considering that the assessing officer has reason to be...