Even prior to assessment year 2008-09, when rule 8D was not applicable, the AO had to enforce the provisions of sub-section (1) of section 14A

LIC Housing Finance Ltd Vs DCIT (ITAT Mumbai)- Issue 1 – Whether where all the facts regarding the amount written off for non-convertible debentures are considered by the AO in the original assessment, reassessment proceedings cannot be initiated by issuing notice u/s 148 merely on change of opinion-? Hon’ble jurisdictional High Court in the case of Asian Paints Ltd. Vs. DCIT and Others, 308 ITR 195 has held that issuance of notice u/s 148 of the Act for the reason that some material which was available on record while making assessment was inadvertently excluded from consideration amo...