- (1.) The petitioner-Minda HUF Limited has challenged reassessment proceedings under Section 147/148 of the Income Tax Act, 1961(Act, for short) initiated vide notice dated 18 th April, 2007 for the assessment year 2003-04. They have also prayed for quashing of the order dated 15 th October, 2007 passed by the Assessing Officer, the respondent No. 2 herein rejecting the objections raised by the petitioner to the reassessment proceedings and holding that they were valid grounds for initiation of reassessment.
(2.) For the assessment year 2003-04, the petitioner had filed their return on 2 nd December, 2003 and an assessment order under Section 143(3) was passed on 28 th March, 2006. The taxable income was enhanced from Rs.2,78,95,579/- as declared in the original return to Rs.3,18,14,069/- in the assessment order dated 28 th March, 2006. We are not concerned with the additions made, which were later on made subject matter of appellate proceedings.
(3.) After reassessment notice under Section 147/148 of the Act dated 18 th April, 2007 was served, the petitioner filed the same return as was originally filed and requested the respondent No. 2 to furnish the reasons recorded for reopening of the assessment.;