Reopening of assessment merely on Internal Audit Objection Not Justified

Lionbridge Technologies P. Ltd. Vs ACIT (ITAT Mumbai) The issue under consideration is whether the re-opening of assessment u/s 147 initiated by AO is justified in law? In the present case, ITAT state that, it is evident from the records that the re-assessment was made on the basis of the internal audit objection much after the elapse of four years from the end of relevant A.Y. 2008-09 i.e. from 31.03.2009. More so, a plain reading of the reasons for re-opening of assessment under section 148 of the Income Tax Act, 1961 has not pointed out as to how the assessee failed to disclose fully and tr...