INCOME TAX ACT, 1961

--Reassessment--Full and true disclosureIssue of notice under section 148--Assessment of assessee was reopened on grounds that income chargeable to tax had escaped assessment amounting to Rs. 98.46 lakhs on account of amount not offered for tax under section 41. Further, assessee had reduced gross dividend income from its income for computing taxable income instead of reducing net dividend income after accounting for expenses relating to earning dividend income, etc. Assessee filed writ petition which was dismissed by High Court Honda Siel Power Products v. Dy. CIT (2012) 340 ITR 53(Del.) [(2011) 39 (I) ITCL 124 (Del-HC)] stating that assessee had not stated anything or given factual matric to justify and state that material facts had been fully and turely disclosed. Court felt that reassessment could be sustained. Assessee filed Special Leave Petition. Held: Reassessment was fully justified on facts and circumstances of the case. However, on merits of the case it would be open to assessee to raise all contentions with regard to amount of Rs. 98.96 lakhs being offered to tax as well as its contention on section 14A. Subject to this Special Leave Petition was dismissed.