The Notice itself does not indicate the approximate amount of income, which the Assessing Officer has reason to believe has escaped assessment- Bombay High Court in Khubchandani Healthparks

It is settled position in law that the decision of the Court has to be read in the context of the facts involved therein and not on the basis of what logically flows therefrom as held by the Supreme Court in Ambica Quarry Works Vs. State of Gujarat, 1987(1) SCC 213. The Apex Court in Zuari Estate Development and Investment Co. Ltd. (Supra)not having dealt with the issue of reason to believe that income chargeable to tax has escaped assessment on the part of the Assessing Officer in cases where regular assessment was completed by Intimation under Section 143(1) of the Act, it would not be wise for us to infer that the Supreme Court in Zuari Estate Development and Investment Co. Ltd. (Supra) has held that the condition precedent for the issue of reopening notice namely, reason to believe that income chargeable to tax has escaped assessment, has no application where the assessment has been completed by Intimation under Section 143(1) of the Act. The law on this point has been expressly laid down by the Apex Court in the case of Rajesh Jhaveri Stock Brokers P. Ltd. (Supra) and the same would continue to apply and be binding-Bombay High Court in Khubchandani Healthparks

It is settled position in law that the decision of the Court has to be read in the context of the facts involved therein and not on the basis of what logically flows therefrom as held by the Supreme Court in Ambica Quarry Works Vs. State of Gujarat, 1987(1) SCC 213

Supreme Court has affirmed the decision of Allhabad High Court in Society for The Promotion of Education Adventure Sports on 16-02-2016 allowing deemed registration of trust after six months where registration not granted in six months. Earlier Allahabad High Court full bench in Muzafarnagar Development Authority on 05-02-2015 had reversed division bench decision in Society for The Promotion of Education Adventure Sports which now stands restored back . Earlier CBDT vide Instruction dated 06-11-2015 had also directed to follow the time limit of six months strictly.