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2021 (9) TMI 11 - ITAT MUMBAIReopening of assessment u/s 147 - AO jurisdiction for reopening the concluded assessment - notice beyond the prescribed period of 6 years - Addition u/s 68 on unexplained cash credit - HELD THAT:- As in the case before us the notice u/s. 148, had been served on the assessee for the first time on 25.06.2013 i.e. beyond the prescribed period of 6 years from the end of the relevant assessment year which expired as on 31.03.2013, therefore, respectfully following judgment of Harjeet Surajprakash Girotra [2019 (7) TMI 941 - BOMBAY HIGH COURT] we are of the considered view that the A.O. had invalidly assumed jurisdiction for reopening the concluded assessment of the assessee company and passed the reassessment order u/s. 143(3) r.w.s. 147, dated 24.03.2014. Accordingly, we herein in the backdrop of invalid assumption of jurisdiction by the A.O. u/s. 147 of the Act quash the reassessment order passed by him u/s. 143(3) r.w.s. 147. - Decided in favour of assessee.
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