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2019 (12) TMI 680 - ITAT JAIPURValidity of reopening of assessment - HELD THAT:- For assumption of jurisdiction, in the reasons so recorded by the Assessing officer, he has stated that assessee has failed to fully and truly disclose all material facts necessary for the assessment. Apparently, the Assessing officer has drawn reference to the proviso to section 147 of the Act which in our mind is not applicable in the instant case as the original return so filed by the assessee was processed u/s 143(1) and not under section 143(3) and thus, the proviso to section 147 and the condition so specified therein cannot be invoked to invoke assumption of jurisdiction u/s 147 of the Act. Basic requirement for assumption of jurisdiction u/s 147 is not satisfied in the instant case and consequent reassessment proceedings deserve to be set-aside - Appeal filed by the assessee is allowed.
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