Income earned by subsidiary from reinvestment of sum infused by Indian Holding Co. couldn’t be taxed

IT/ILT : Where AO sought to reopen assessment taking a view that income of assessee's wholly owned foreign subsidiary company was not offered for taxation, in view of fact that there was no failure on part of assessee to disclose all material facts at time of assessment, initiation of reassessment proceedings after expiry of four years from end of relevant assessment year was bad in law