S. Ravindra Bhat, J.

C.M.No.2745 of 2014 (for exemption)

Allowed, subject to all just exceptions.

W.P.(C) 1320/2014, C.M. No.2744/2014

1. The petitioner challenges the notice dated 25.03.2013 under Section 148 of the Income Tax Act (“the Act”) proposing to re-open the assessment for Assessment Year 2006-07 @ Rs.1,12,760/- completed under Section 143 (3) by the Assessing Officer (“AO”).

2. The brief facts are that the petitioner filed income tax returns on 30.10.2006 for AY 2006-07. The returns were selected for scrutiny; a notice was issued on 28.02.2008 along with a questionnaire. The required details were furnished by the petitioner on 07-03-2008. The AO, accepting the explanations, framed the assessment on 28-03-2008. In this background of circumstances, the respondent AO sought to re-open the assessment by the impugned notice, under Section 147 of the Act. Responding to this notice, the assessee, on 22-04-2013 stated that it stood by the returns filed originally (and accepted by the AO on 28-03-2008); it also requested that the reasons for re-opening the assessment be furnished.

3. The Revenue acceded to the petitioner’s request; the reasons furnished are extracted b