Tangible material must to satisfy test of reopening

Tata Consultancy Services Ltd. Vs DCIT (Bombay High Court) GIST :- The query so raised was responded to by the petitioner which was before the Assessing Officer. Finally, an order of assessment came to be passed on 3rd January 2022 wherein the claim was not disallowed. It, therefore, is clear that the issue with regard to the claim of deduction on account of payment made to settle a class action suit was not so embedded in the documents as could not with due diligence have been noticed by the Assessing Officer rather in this case, the claim had been noticed, queries raised, response called, wh...