Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2014 (2) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (2) TMI 27 - DELHI HIGH COURTValidity of re-opening of assessment u/s 147 - Held that:- The omission to discuss or deal with material furnished in the course of original assessment proceedings, cannot result in formation of “reasons to believe” under Section 147 - In assessee's case, each of the materials in respect of the four firms and the other documents were put to the assessee in the course of original assessment proceedings which culminated in the order of 29.09.1993 - Relying upon the decision in Commissioner of Income Tax Vs. Kelvinator of India Limited [2010 (1) TMI 11 - SUPREME COURT OF INDIA] - The reasons recorded by the AO were merely change of opinion - Decided in favour of petitioner.
|