Section 148 Notice issued after expiry of 4 years, based on Addl. CITs approval, is unsustainable

Voltas Limited Vs ACIT (Bombay High Court) Facts- Petitioner is a company engaged in the business of air conditioning and refrigeration etc. During the A.Y. 2015-16, petitioner incurred expenses of Rs.3,30,82,713 towards CSR as per section 135 of the Companies Act, 2013. Petitioner had also claimed deduction in return of income u/s 35AC and 80G of the Act for donations made to various institutions. Petitioner’s ROI was selected for scrutiny and assessment order came to be passed u/s 143(3) read with section 92CA of the Act on 18.02.2019. During the course of assessment proceedings, petitione...