Reopening Unjustified: No Link Between Available Material & Belief of Escaped Income

CIT Vs Spirit Global Construction Pvt. Ltd. (Delhi High Court)

Delhi High Court held that the reasons disclosed for re-opening do not allude to the material that was available to the AO which persuaded him to form a belief that income had escaped assessment. Hence, prerequisite before entering the realm of reassessment/assessment proceedings not met. Accordingly, addition not sustainable.

Facts- Spirit Global Construction Pvt Ltd (SGCPL) had filed its Return Of Income [“

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