Reopening u/s. 148 based on grossly erroneous factual foundation is untenable-in-law: Madras HC

FIVES India Engineering & Projects Private Limited Vs ITO (Madras High Court)

Madras High Court held that reopening of assessment under section 148 of the Income Tax Act based on a grossly erroneous factual foundation and also based on mechanically granted approval is untenable in law.

Facts- The petitioner and Fives France under the Assistance Service Agreement between said parties, the petitioner had filed AAR seeking a ruling mainly on the question that whether paym

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