S. 147


Export Credit Guarantee Corporation of India Ltd v Addln CIT Writ Petition No. 502 of 2012 (order dtd January 10/11, 2013) – Bombay HC Background: Assessee filed a return of income for AY 2006-07 on 28 November 2006 in which it offered income computed at Rs. 385.25 crores to tax under Section 44. An order of assessment was made on 17 November 2008 under Section 143(3) by which the total income was determined at Rs.386.08 crores after making certain disallowances. A notice was issued on 24 March 2011 to the assessee seeking to reopen the assessment. The assessee by a letter dated 18 November 2011 objected to the notice proposing to reopen the assessment for A.Y. 2006-07. The Assessing Officer by his order dated 22 November 2011 disposed of the objections. 

Full disclosure in the return of income does not preempt the AO from reassessment – ...