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2012 (9) TMI 609 - GUJARAT HIGH COURTValidity of notice issued u/s 148 on March 21, 2003, in respect of the AY 1996-97 which is beyond a period of four years from the end of the relevant AY, in the absence of any failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment - dis-allowance u/s 40(a)(ia) - payment of usance interest to nonresidents out of the boundaries of India on purchase of ships - Held that:- A perusal of the reasons recorded shows that there is not even a whisper therein to the effect that there is any failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment for the assessment year under consideration. Under the circumstances, the notice having been issued after the expiry of a period of four years from the end of the relevant assessment year, the assumption of jurisdiction u/s 147 by the Assessing Officer is without authority of law - Decided in favor of assessee
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