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2013 (12) TMI 1162 - ALLAHABAD HIGH COURTWhether the report of ADI (Investigation) may be the basis for initiating proceedings u/s 147 - Held that:- The condition that the A.O. must be in possession of a definite and relevant information or material which may led him to have reasons to believe that income chargeable to tax has escaped assessment must be fulfilled - The Tribunal is a final fact finding authority - The Tribunal observed that the mandatory conditions for initiation of the proceedings u/s. 147 were not fulfilled in the case of the assessee. Also the tax effect in each appeal is less than prescribed limit - As per Board's Circular dated 24.10.2005 as well as limit prescribed under Section 268-A of the Income Tax Act, the Department is not expected to file the appeals - Decided against Revenue.
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