(M.R. Shah and Krishna Murari, JJ.)
Special Leave Petition (Civil) Diary No. 15246/2020, decided on September 6, 2022
Pr. Commissioner of Income Tax 2 _____________________ Petitioner;
v.
Tata Sons Ltd. ____________________________________ Respondent.
(For Admission and I.R. and IA No. 78775/2020-Condonation of Delay in Filing and IA No. 78777/2020-Exemption From Filing C/C of the Impugned Judgment IA No. 78775/2020 – Condonation of Delay in Filing IA No. 78777/2020 – Exemption From Filing C/C of the Impugned Judgment)
Special Leave Petition (Civil) Diary No. 15246/2020; ITA No. 639/2017; IA No. 78775/2020; and IA No. 78777/2020
The Order of the court was delivered by
Order
1. Delay condoned.
2. Having heard Shri N. Venkataraman, learned ASG appearing on behalf of the petitioner and having gone through the impugned judgment and order passed by the High Court, it appears that the reasons to re-open the assessment were recorded after issuance of the re-assessment notice and, therefore, it can be seen that at the time when the notice for assessment was issued, there was no subjective satisfaction, the High Court has not committed any error in setting aside re-assessment proceedings. We are in complete agreement with the view taken by the High Court. The Special Leave Petition stands dismissed.
3. Pending application(s) shall stand disposed of.
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