Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (1) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (1) TMI 1498 - ITAT MUMBAIValidity of reopening u/s 147 - change of opinion - Held that:- Details of Shareholders and complete details of increase in share capital including name of shareholder, Address, PAN and confirmation. The assessee, in reply, provided the details of shareholders, PAN, Address, Share Application form, Confirmation from respective applicants along with their Board resolutions, Return of allotment, Board resolution of the assessee company regarding Share Allotment etc. After appreciating the same, the assessing officer concluded the assessment. Above facts show that the assessee has disclosed all material facts at relevant places during original assessment proceedings u/s 143(3) of the Act. The AO himself asked for specific questions and full details were supplied by the assessee. AO examined these documents and framed the assessment only after proper application of mind. There was no failure on the part of the assessee to fully and truly disclose all the material facts. Thus, reassessment is being sought by the AO on mere change of opinion and apparently on the basis of information received from the investigation wing but nevertheless, all the information was available before AO during original proceedings. - Decided in favour of assessee.
|