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2013 (12) TMI 549 - ALLAHABAD HIGH COURTValidity of reassessment u/s 147 - Held that:- The perusal of the reasons showed that the escapement of income from assessment had been attributed not to any existing material, but on assumption of state of things to exist for the reasons best known to the AO - The information received from the office of the ld. CIT (A)-I, Agra was wholly vague and incorrect regarding sale of flats by the assessee firm - Examination of the balance sheet made it clear that the assessee did not sell any flat in the assessment year under appeal - The reasons recorded by the AO for reopening of assessment was based on incorrect and non-existing facts - There was no evidence, document or material in possession of the AO to prove that the assessee had in fact sold any flat in the assessment year under appeal - The ld. CIT (A) is also not justified in confirming the reopening of assessment on the ground that the additions made by the AO are connected with the reasons as recorded to the construction business - Decided against Revenue.
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