Non-consideration of certain information during original assessment is valid ground for reopening of assessment

Cognizant Technology Solutions India P. Ltd. Vs Asst.CIT (Madras High Court) Facts- Impugned notice was issued under section 148 for reopening of the assessment. The petitioner questioned the legal validity of the initiation of the reopening proceedings. Conclusion- If the Assessing Officer has reason to believe that the particular issue has not been considered or scrutinised during the course of original assessment proceedings, then he is empowered to reopen the assessment under Section 147/148 of the Act. Thus, Section 147 provides an opportunity to the Revenue to reopen the proceedings if t...