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2010 (8) TMI 617 - HC - Income TaxAddition - Reopening - Time barred - it is apparent that where an assessment under section 143(3) has been made, as in the present case, no action can be taken under section 147 of the Act, 1961 after expiry of four years from the end of the relevant assessment year unless the assessee had omitted or failed either to make a return under section 139 of the Act, 1961 for he year or had failed to respond to a notice under section 142(1) or under section 148 of the Act, 1961 or had failed to disclose fully and truly all the facts necessary for his assessment - in the present case as none of the conditions precedent for invoking the first proviso to section 147 had arisen, the Assessing Officer could not have assumed jurisdiction under section 147 - Appeal is dismissed
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