AVTEC LIMITED Vs. DEPUTY COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) This writ petition is directed against the notice dated 28.03.2013 issued under Section 148 of the Income-tax Act, 1961 (hereinafter referred to as "the said Act") whereby the petitioner's assessment for the assessment year 2006-07 is sought to be re-opened. The petition is also directed against the order dated 14.03.2014 whereby the Assessing Officer has rejected the objections raised by the petitioner pursuant to the issuance of the impugned notice dated 28.03.2013.

(2.) The original assessment under Section 143(3) of the said Act was made on 24.12.2008. The notice under section 148 has been issued beyond four years from the end of the assessment year 2006-07, therefore, the proviso to section 147 would come into play.

(3.) The recorded reasons for initiating the re-assessment proceedings are as under:-