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2011 (3) TMI 17 - HC - Income TaxRe-assessment - Search and seizure - additional income suppressed by the assessee – Whether Assessing Officer had any competence, jurisdiction and authority under Section 148 to reopen the proceeding on a mere change of opinion when there was no new or fresh information before him while making reassessment but which was there at the time of making the original assessment - earlier proceeding as regards the income from the sale of the land, such amount cannot be taxed as revenue receipt and that the assessee was prepared to pay capital gain tax on the sale proceeds on account of the sale of those plots of land - assessee had concealed the particulars of the additional sale proceeds, which were obtained from the seizure of books, the fate of such additional amount will also abide by the result of the earlier concluded proceedings between the parties – Appeal dismissed
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