Paris Elysees India Pvt. Ltd. vs. DCIT

Parties Involved

Facts Summary

The assessee, Paris Elysees India Pvt. Ltd., filed an appeal against the order of the National Faceless Appeal Centre, Delhi, dated 31/07/2023, for the assessment year 2012-13. The assessee had filed an appeal against the order passed by the ACIT, Circle-07, Jaipur, dated 05.12.2019. The assessee raised issues regarding the reopening of the assessment under section 147, the issuance of notice under section 148 without proper sanction, and the addition of Rs. 83,74,399/- under clause (i) of Explanation 1 of section 115JB. The assessee argued that the amount written off as an advance against capital commitment should not be added back in the computation of book profits under the Minimum Alternate Tax (MAT) provisions.…

Legal Issues

• 1. Reopening of the assessment under section 147
• 2. Issuance of notice under section 148 without proper sanction
• 3. Addition of Rs. 83,74,399/- under clause (i) of Explanation 1 of section 115JB

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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