Section 147 Notice Invalid: AO Failed to Record Satisfaction & Disclosure Lapses Beyond 4-Year Limit

CIT Vs Schwing Stetter India P. Ltd. (Madras High Court) The Madras High Court recently dismissed an appeal filed by the Revenue in the case of CIT v. Schwing Stetter India P. Ltd., affirming the decisions of the Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal. The core of the dispute revolved around the validity of reassessment proceedings initiated by the Assessing Officer (AO) beyond the four-year statutory period. Background of the Case: The assessee, Schwing Stetter India P. Ltd., is a manufacturer of concrete mixtures, pumps, and related components. For the ass...