ITAT Chennai Upholds Reassessment u/s 147 Based on Correct Understanding of Facts

Titan Company Limited Vs ACIT (ITAT Chennai)

ITAT Chennai held that initiation of proceedings under section 147 of the Income Tax Act confirmed by CIT(A) based upon correct understanding and appreciation of facts of the case vis-à-vis contemporaneous statute justifiable.

Facts- AO had initiated u/s 147 proceedings for two reasons firstly that as per form 10CCB for the new undertaking, established by the assessee in Pant Nagar district of Uttranchal State, a claim of Rs. 3,72,05,815/- was made u/s 80C(2)(a)(ii) was made. The new undertaking commenced its ope

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