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2012 (2) TMI 158 - HC - Income TaxValidity of notice issued u/s 148 beyond a period of four years from the end of the relevant A.Y. - manufacturer of jewellery in a SEZ – deduction u/s 10A - assessment order for A.Y. 05-06 framed u/s 143(3) – reopening sought on the basis of the findings contained in the assessment order for A.Y. 07-08 - Held that:-A.O. having failed to establish that there was a failure on the part of the assessee to disclose fully and truly all material facts for A.Y. 05-06, the reopening beyond a period of four years is clearly not valid. There was a finding of fact by the A.O. in the assessment order for A.Y. 2005-06 that the business activity of the assessee is manufacturing of jewellery in a Special Economic Zone entitling deduction u/s 10A – Decided in favor of assessee.
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