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2012 (5) TMI 27 - PUNJAB AND HARYANA HIGH COURTRevised return declaring Nil income after claiming deduction u/s 80HHC and 80IB - Revenue stated that no deduction u/s 80IB available as the machinery was found to have been used previously for some other purpose – AO issued notice for reassessment - Held that:- No concealment on the part of the assessee in disclosing the facts to the Assessing Officer, thus not open to the AO to invoke the provisions of Section 148 for the purposes of reassessment - change of opinion on the same facts cannot constitute basis for exercise of jurisdiction under Section 147/148 – in favour of assessee.
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