The Royal Bank of Scotland N.V.-India Branch(amalgamated with NatWest Markets Plc-India Branch) Vs DCIT, International Taxation- 2(1), Kolkata

Parties Involved

Facts Summary

The Assessing Officer (AO) issued an original notice under section 148 of the Act on 30.06.2021. The assessee was given notice under section 148A(b) of the Act on 23.05.2022. Thereafter, the order under section 148A(d) of the Act was passed on 25.07.2022 after taking into account the submissions of the assessee, and notice was finally issued under section 148 of the Act on 25.07.2022 to the assessee after obtaining the approval from the competent authority i.e. CIT(IT & TP), Kolkata dated 19.07.2022. The assessee contended that the reopening of the assessment was not sustainable as the approval accorded under section 151 of the Act was not in accordance with law.…

Legal Issues

• 1. Whether the approval obtained under section 151 of the Act was in accordance with law.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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