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2012 (5) TMI 202 - AT - Income TaxReassessment - Notice u/s 148 - Addition on account difference in revenue booked in P & L A/c and TDS Certificates - held that:- not only the return of income stood assessed but also the proceedings u/s.154 have been concluded after the assessee has submitted its reply. After all these stages reopening u/s.147 has been initiated by an issuance of notice u/s.148 dated 25.03.2009. On this background, the validity of the proceedings u/s.147 has been challenged before us in the additional grounds. - The case is covered directly by the ratio and law laid down by the Hon'ble Calcutta High Court in the case of Berger Paints India Ltd. (2009 -TMI - 76496 - CALCUTTA HIGH COURT) - assessment proceedings u/s 147 quashed.
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