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2012 (6) TMI 409 - HC - Income TaxReview petitions by the Revenue – reopening concluded assessments – dis allowance under Section14A – Held that:- If the Revenue's claim is allowed, then the prohibition under the proviso against the AO to revise concluded assessments for making disallowance under Section 14A can be neutralized and defeated by referring concluded assessments to the Commissioner for initiating suomoto revision power under Section 263 - as in the case of concluded assessments the proviso makes it clear that the assessee should not be subjected to disallowance either by reopening assessment under Section 147 or under Section 154 for raising demand of tax after disallowance or for withdrawing refund granted – review petition dismissed – against revenue.
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