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2021 (1) TMI 729 - ITAT MUMBAIReopening of assessment u/s 147 - proceedings beyond 4 years - HELD THAT:- As held in the case of PCIT versus Light Carts (P) Ltd [2017 (9) TMI 46 - ALLAHABAD HIGH COURT] that where assessee disclosed all the material facts necessary for assessment, AO could not reopen assessment after expiry of 4 years from the end of relevant year merely on the basis of information supplied by investigation wing that certain income earned by assessee had escaped assessment. We are inclined to quash the reassessment order based on the fact that it is reopened beyond 4 years without bringing on record any failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. The order passed by Ld. CIT(A) that the assessment was reopened within 4 years and he proceeded to adjudicate the issue on reopening of the assessment in the above said wrong notion and sustained the addition made by the assessing officer. It is brought on record clearly that the reassessment was initiated beyond 4 years, therefore we restrict ourselves to adjudicate on jurisdiction issue and not going into merits of the case - Decided in favour of assessee.
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