SC dismisses
assessee-company’s SLP challenging Bombay HC order upholding re-assessment
initiation (beyond 4 yrs period) based on a special audit report; HC had held
that the special audit report constituted fresh tangible material with AO to
reach the reasonable belief of income escapement; HC had rejected assessee’s
stand that since the special audit report was prepared for Forward Market
Commission, it could not be relied upon as its purpose was not to detect tax
evasion; HC had opined that “the power of the AO to reopen an assessment...is
not fettered or circumscribed, to be formed only on material found during a tax
audit or with material found during examining a case of tax evasion.”:SC
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