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2004 (7) TMI 33 - HC - Income TaxReassessments - reason to believe - "Whether Tribunal was right in holding that the reassessments were completed by the Assessing Officer without reason to believe that income has escaped assessment and therefore the reassessments are liable to be set aside?" - Assessing Officer relied upon the confession alleged to have been made by the assessee obtained on the date of search to the effect that she had failed to disclose certain income and jewellery at the time of search. However, the Tribunal, without relying upon the confession statement, took cognizance of the explanation offered to that, viz., that the jewellery and precious stones were presented as gift on the occasion of the marriage of the assessee's daughters and the amounts of Rs. 7,000 and Rs. 1,500 per year were the personal drawings and the commission on purchase and sale of semi-precious and precious stones respectively. - Since the issue whether there were materials for the appellant/Revenue to invoke section 147 are sufficient, bona fide, definite, relevant and reliable is purely a matter of fact, finding no substantial question of law, the appeals are dismissed.
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