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2004 (3) TMI 13 - HC - Income TaxReopening the assessment after the expiry of four years - jurisdiction of the Assessing Officer to initiate the proceedings which were barred by time - It is apparent from the reasons that the Assessing Officer did not hold any belief that escapement of income chargeable to tax from the assessee was on account of any failure on the part of the assessee to disclose truly and fully all material facts necessary for his assessment for the assessment year 1996-97. Thus, it was clearly a case falling within the ambit of the proviso to section 147 and notices issued after January 31, 2001, were clearly barred by time. Thus, the Assessing Officer had no jurisdiction to issue the notices.
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