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Reopening u/s 147 quashed – AO’s “fishing enquiry” to investigate offshore receipts not valid formation of belief- Reassessment void where AO reopens only to verify PE/offshore claims
Case Law Details
- Case Name
- Huawei International Pte. Ltd. Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2014-15
- Courts
- All ITAT, ITAT Delhi
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Huawei International Pte. Ltd. Vs ACIT (ITAT Delhi)
Reopening u/s 147 quashed – AO’s “fishing enquiry” to investigate offshore receipts not valid formation of belief- Reassessment void where AO reopens only to verify PE/offshore claims
Assessee, a tax resident of Singapore, engaged in providing ICT infrastructure solutions, challenged the reassessment order dated 30-03-2024 passed u/s 147 r.w.s 144C(13) in conformity with the DRP’s directions. The dispute arose from reopening of assessment for A.Y. 2014-15 based on information that Huawei International Pte Ltd had re...
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