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2010 (2) TMI 961 - GUJARAT HIGH COURTReassessment - Notice u/s 148 - held that:- In the facts of the case that is not so as there was no evidence required with regard to the disclosure made for transfer of an undertaking and if any clarification was required, thereof with regard to any bifurcation or classification, the Assessing Officer could have called for the said clarification once the asses-see had made the declaration. Therefore, in the facts of this case, it cannot be said that after such disclosure the assessing authority may not have noticed the necessary material and relevant facts. Further, it cannot be said that there was no disclosure of primary facts which has caused the escapement of the income.
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