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2010 (2) TMI 931 - AT - Income TaxReassessment proceedings under section 147 of the Income-tax Act - additions on the merits on account of bogus purchases, cash credit, part gross profit addition and other disallowances of the expenditure - Assessing Officer is, however, directed to reopen the assessments for the assessment years 1998-99, 1999-2000, 2000-01 and 2001-02 under section 147 – Held that:- reasons recorded by the Assessing Officer did not find facts and the satisfaction of the Assessing Officer for escapement of income. In the absence of the fulfilment of the requirements of section 147 of the Income-tax Act for initiation of the reassessment proceedings in the above cases, since the reopening of the assessments would have been done by recording the reasons only by the Assessing Officer, therefore, there was no reason for the assessee to have challenged the findings of the learned Commissioner of Income-tax (Appeals) in the appellate order, orders of the authorities below set aside and quash the reassessment proceedings under section 147 of the Income-tax Act, assessee are allowed and both Departmental appeals are dismissed.
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