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| The Tax Publishers2019 TaxPub(DT) 2038 (SC) : (2019) 262 TAXMAN 0369 INCOME TAX ACT, 1961
Section 261 Section 147
Where the department preferred SLP to appeal against the judgment of Delhi High Court in FIS Global Business Solutions India (P) Ltd. v. Asstt. CIT (2018) 408 ITR 75 (Del) : 2018 TaxPub(DT) 6799 (Del-HC), whereby the High Court held that Audit Objection was merely information and subsequent audit report could not be considered as tangible material, that since it was settled law that mere change of opinion could not form basis for issuing notice under section 147/148, reassessment notice issued to assessee was not sustainable, the Supreme Court condoned delay and dismissed the SLP.
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Appeal (Supreme Court) - Special leave petition - Reassessment - Change of opinion--Absence of tangible material
Department preferred SLP to appeal against the judgment of Delhi High Court in FIS Global Business Solutions India (P) Ltd. v. Asstt. CIT (2018) 408 ITR 75 (Del) : 2018 TaxPub(DT) 6799 (Del-HC), whereby the High Court held that Audit Objection was merely information and subsequent audit report could not be considered as tangible material, that since it was settled law that mere change of opinion could not form basis for issuing notice under section 147/148, reassessment notice issued to assessee was not sustainable.Held: The Supreme Court condoned delay and dismissed the SLP.
Affirmed:FIS Global Business Solutions India (P) Ltd. v. Asstt. CIT (2018) 408 ITR 75 (Del) : 2018 TaxPub(DT) 6799 (Del-HC).
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