Reassessment not valid if Material facts already been disclosed during Original Assessment

HIGH COURT OF DELHI Director of Income-tax Versus McDonalds Corporation IT APPEAL NOS. 908 & 909 OF 2011 DECEMBER 11, 2012 JUDGMENT S. RavindraBhat, J. In these appeals the Revenue impugns a common order of the Income Tax Appellate Tribunal (‘Tribunal’, for short) dated 18.02.2011 made in ITA No. 4433 & 4434/Del/2010. The common question of law framed is as follows: – “Whether the Income Tax Appellate Tribunal was right in holding that jurisdictional pre-condition for issuance of notice under Section 147/ 148 of the Income Tax Act, 1961 are not ...