No power to Designated Authority to reopen concluded cases under Vivad se Vishwas Act

S A N Garments Manufacturing Private Limited Vs PCIT (Delhi High Court)

Conclusion: There was no provision under the DTVSV Act that empowered a Designated Authority to reopen a concluded settlement. Once a final certificate was issued under Section 5(1), all disputes with regard to the ‘tax arrear’ stood concluded.

Held: AO passed an assessment order under Section 147 read with Section 143(3) determining assessee’s income for the AY 2012-13 at ₹16,73,57,840/- after making an addition of ₹3,07,39,590/- as undisclosed ex

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