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2016 (4) TMI 1365 - BOMBAY HIGH COURTReopening of assessment u/s 147 - escapement of income to tax income from M/s. Reliance Petrochemicals Ltd. - HELD THAT:- It is beyond our comprehension as to how the RespondentAssessee could have foreseen during the Assessment proceedings that the Assessing Officer will not bring to tax the income alleged to have earned from M/s. Reliance Petrochemicals Ltd. to tax. In any case, so far as this Court is concerned, it is a settled issue that in the absence of the Assessing Officer bringing to tax any income earned from the source recorded in the reasons as having escaped assessment in support of the impugned notice, the Assessing Officer has no jurisdiction to bring to tax income earned/received from any other source by the assessee. This is a jurisdictional requirement as held by this Court in Jet Airways [2010 (4) TMI 431 - HIGH COURT OF BOMBAY] . In view of the fact that the issue arising herein stands concluded by the decision of this Court in Jet Airways (supra) no substantial question of law arise for our consideration.
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