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2004 (3) TMI 59 - HC - Income TaxNotice of reassessment – limitation - prima facie satisfaction about the escapement of income - the assessee cannot draw any support from this document for challenging the validity of the proceedings under section 147 - the statement of Shankar Hari Maheshwari cannot be said to be vague. He had clearly denied having any account in the Punjab National Bank, and had further stated that if there was such an account, it might have been opened by someone farzi in his name with which he had no concern. In view of this categorical stand, it was not necessary for the Assessing Officer to further confront him with any specific transaction in the said account for recording a prima facie satisfaction about the escapement of income – Notice after four year was valid
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