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2009 (8) TMI 802 - AT - Income TaxReassessment - Unexplained Investment - Time limitation - Search and seizure - assessee submitted in reply to question No. 61 that the aforesaid FDRs were purchased in the name of his wife Smt. Ranidevi C. Singh and FD of Rs. 5,000 in the name of his daughter was included in the aforesaid amount - In CIT vs. DCM Ltd., Hon'ble High Court found that there was no allegation in the reasons recorded by the AO that the assessee had failed to file its return or that it had failed to disclose fully and truly all material facts in its return nor was there any allegation by the AO that assessee had failed to disclose fully and truly all material facts in its return income nor even there was any allegation regarding escapement of income these circumstances, Hon'ble High Court upheld that findings of the Tribunal, notice under s. 148 of the Act, having been issued after four years, the reopening the assessment was not valid - Appeals are allowed
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