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2011 (10) TMI 594 - AT - Income TaxReopening of assessment - reasons to believe - addition made by the AO on account of share capital money received by the assessee - Held that:- The reassessment proceedings initiated by the AO are without jurisdiction and invalid in the eyes of law inasmuch as the reasons recorded by the AO do not satisfy the requirement of section 147 of the Act. We, therefore, uphold the order of the learned CIT(A) in holding that the proceedings initiated by the AO under sec. 147 of the Act are without jurisdiction and invalid, however, for the reasons given by us. Thus, the ground of the revenue regarding the validity of assessment proceedings initiated u/s 147 of the Act is rejected in both the Assessment Years under appeal. Appeals filed by the revenue are dismissed.
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