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2012 (8) TMI 424 - AT - Income TaxReopening of assessment u/s 147 - capital gains had arisen because of a sale deed executed on 13.3.1994 belongs to the AY 19994-95 & not in AY 1997-98 - Held that:- As no valid notice u/s 143(2) was issued within one year of filing of the return of income and AO without even dealing with the factual aspect of the plea has declined it by citing ‘ principle of estoppel' the same is not sustainable because the plea challenging the validity of the assessment goes to the root of the case and if the assessment itself is held to be bad in the eyes of law nothing further survives - in favour of the Assessee
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