Reassessment solely based on Audit Objection is barred by Provisions of Section 147/148

FIS Global Business Solutions India Pvt. Ltd. Vs PCIT (Delhi High Court)

Reliance by the Revenue upon an audit report, cannot be considered as tangible material. This Court is of the opinion that Carlton Overseas Pvt. Ltd. v. Income Tax officer & Ors., (2009) 318 ITR 295 concludes the issue in the present case; the audit objection merely is an information. As reiterated in Kelvinator (supra) by the Supreme Court, change of opinion is impermissible. The Revenue was clearly barred by provisions of Section 147/148 of the

Please become a Premium member. If you are already a Premium member, login here to access the full content.