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2014 (4) TMI 977 - ITAT DELHIValidity of re-opening of assessment u/s 148 of the Act – Contrary view taken by the AO - Held that:- The fact regarding the provision for doubtful debts and advances was duly disclosed by the assessee in the profit & loss account which was filed along with the return - The assessee has also added back the provision in the computation of income under the normal provision but the same was not included in computing the book profit u/s 115JB - the fact regarding the provision in respect of doubtful debts was duly disclosed by the assessee. The findings of the AO is contrary to his own finding wherein the AO himself has mentioned that the assessee company has debited Rs.34,02,529/- to the profit & loss account as provision for doubtful debts and advances and which was written back in the computation of income under the normal provision - it is evident that the assessee has disclosed all facts relating to the provision for doubtful debts and advances – thus, reopening of the assessment beyond four years wherein the original assessment was completed u/s 143(3) was not permissible – thus, the notice is set aside – Decided in favour of Assessee.
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