Reassessment based on material available during original scrutiny assessment not permitted

Precilion Holdings Limited Vs DCIT (Bombay High Court) Conclusion: AO was not permitted to reopen assessment merely because in the later year, he took a different view on the basis of similar material available at the time of original scrutiny assessment as there was no failure on the part of assessee to disclose truly and fully all material facts. Held: Assessee was a company incorporated in Cyprus and engaged in the activity of an investment holding company. During the year, assessee had received interest on compulsory convertible debentures from associated enterprises of assessee. Arm’...