PFIZER LIMITED Vs. DEPUTY COMMISSIONER OF INCOME-TAX

JUDGEMENT

(1.) This petition challenges notice under Sec. 148 of the Income-tax Act,1961 (hereinafter referred to as 'the Act') dtd. 29/3/2016 for the Assessment Year (AY) 2009 -10 seeking to reopen the assessment made on 18/4/2013 under Sec. 143 of the Act. This petition was admitted on 20/12/2016, and the impugned notice dtd. 29/3/2016 was stayed till final disposal of the petition.

(2.) The original income return for AY 2009-10 was filed on 30/9/2009 and revised on 25/3/2011. The return was selected for scrutiny assessment by issuing notice under Sec. 142(1) of the Act.

(3.) During the assessment proceedings, various details were sought for including details relating to promotional expenses and allowability of such expenses in the light of the CBDT Circular No.5 of 2012. The petitioner vide various letters filed the details of these promotional articles and the submissions on allowability of such expenditure in the light of CBDT Circular No.5 of 2012.