No reassessment on the basis of future contingencies resulting in escapement of income

Pavan Morarka Vs ACIT (Bombay High Court) Conclusion: Reopening of an assessment under Section 148 was not justified on the ground that AO was of the opinion that a  contingency might   arise in future resulting an escapement of income which would be wholly impermissible and would amount to a rewriting of the statutory provision. Held:  Assessee held 50% of the equity share capital of Shivum Holdings Pvt. Ltd. (Shivum) and 25% of the equity share capital of P & A Estate Pvt. Ltd. (P&A). Assessee’s wife, Rachana Murarka held 50% of the equity share capital of Shivum and 25% of...