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2005 (1) TMI 73 - HC - Income TaxReassessment proceedings - unexplained investments – ITO invoking provisions of section 147(a) - assessment was finalized by the Assessing Officer without getting an investigation made into the value of the construction. Subsequently, he initiated proceedings under section 147(a) on the basis of the report prepared by the DVO. The Assessing Officer did not have any other material on the basis of which he could have reason to believe that the income of the assessee had escaped assessment or that the assessee had deliberately did not disclose fully and truly his income –Thus, notice issued by the Assessing Officer under section 147(a) was vitiated due to non-application of mind and the Commissioner of Income-tax (Appeals) and the Tribunal did not commit any illegality by setting aside the order of reassessment
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