HIGH COURT OF DELHI
Mitsui & Company India (P.) Ltd.
versus
Income-tax Officer
WP(C) NO. 1121 OF 2012
AND CM NO. 2447 OF 2012
September 26, 2012
ORDER
R.V. Easwar, J.
This writ petition has been filed in the following circumstances. The petitioner is a private limited company. It filed its return of income for the assessment year 2006-07 on 30th November, 2006 declaring a total income of Rs. 12.01 crores. The return was processed under Section 143(1) of the Income Tax Act, 1961 (‘Act’ for short) and it was accepted without any adjustment. On 28th March, 2011 the Assessing Officer recorded the following reasons under Section 148(2) of the Act for reopening the assessment:-
|
“1. |
Name & address of the assessee |
Mitsui & Co. India Pvt. Ltd. |
|
|
2. |
PAN/ GIR | ||
|
3. |
Status | ||
|
4. |
Asstt. Year |
2006-07 |
In this case, the information was received from DAO-45, New Delhi, that the assessee has received amounts in Yen from Mitsui & Co. Ltd. in A Y 2006-07 as under:
| Name |
Address |
Gross income paid currency code |
Gross income paid amount: Major unit of currency |
Actual payer keyname |
F Y |
|
| Mitshui & Co. India Pvt. Ltd. | G Floor, The Metropolitan Centre, Bangla Sahib Road, Gole Market, New Delhi |
JYP |
2665644 |
Mitsui & Co. Ltd. |
2005-06 |
|
| Total |
-Do- |
3430535 |
In view of the above, I have reasons to believe that the income of JPY 2665344 (Rs. 1128644) chargeable to tax has escaped assessment within the meaning of section 147/148 of the Income Tax Act, 1961.
