| 2016-TII-INSTANT-ALL-308 | 29 March 2016 |
BBC WORLDWIDE LTD Vs ADIT : DELHI HIGH COURT (Dated: March 21, 2016) Income tax - Sections 143(1), 143(2), 147 & 148. Keywords - change of opinion - escaped assessment - reopening - reasons to believe - sale of airtime & subscription from hotels. Whether the fact that the AO had not relied on the accounts produced by the assessee and had proceeded to estimate the assessee's income on a presumptive basis for previous A.Ys, can be a reason for the AO to believe that assessee's income had escaped assessment in the current A.Y as well - NO: HC Whether it can be inferred that the notice u/s 148 was issued only on account of change of opinion, where the AO after examining the statement of computation of loss as well as relevent vouchers provided by the assessee found them to be 'satisfactory' during origional assessment - YES: HC Whether the provisions of Section 147 permit review of an assessment order - NO: HC Whether the mere fact that another AO had adopted a different method of estimating the income attributable to a foreign assessee from Indian activities, can be a reason to reopen the assessment - NO: HC Assessee's petition allowed TII BRIEF 11 more unilateral APAs signed TII Circular/Notification Circular/Notification No : 55 Investment by Foreign Portfolio Investors (FPI) in Government Securities |
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