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2013 (12) TMI 1250 - ALLAHABAD HIGH COURTWhether reopening of assessment u/s 147 is permissible on the basis of audit report - Held that:- The audit report was not the only information, which persuaded the assessing authority, to issue notice under Section 142 (1) of the Act - The audit report was submitted on 17.11.2008, and was available on record - The Assessing Officer after examining the judgments of the Supreme Court in Liberty India [2009 (8) TMI 63 - SUPREME COURT] - The AO formed an opinion to issue notice under Section 142 (1) of the Act, fixing 15.06.2012 to submit the specified documents mentioned in the questionnaire attached with the notice dated 31.5.2012. The Assessing Officer did not commit any jurisdictional error in issuing the notices - Decided against petitioner.
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