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2003 (2) TMI 8 - HC - Income TaxReopening of assessment – limitation - reason to believe - In cases of reopening after four years, the Assessing Officer must have reason to believe that income has escaped assessment by reason of failure on the part of the assessee to disclose fully and truly all material facts - In the present case, reopening is sought to be done beyond four years. In the present case, the assessee had filed its annual report before the Assessing Officer indicating spread over of Rs. 10,02,23,735 over a period of 60 months. The Assessing Officer acted on that report by granting deduction to the extent of Rs. 33,40,818 for the year ending March 31,1996. In the circumstances, there was no failure on the part of the assessee to disclose fully and truly the material facts.
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