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2012 (12) TMI 498 - AT - Income TaxIncome from operation of aircrafts - interest on fixed deposit - exemption under Article 8 of Indo-US DTAA. - reassessment u/s 147 - held that:- Since there was no such tangible material before the AO from which he could entertain the belief that income of the assessee chargeable to tax had escaped assessment, the Third Member held that reassessment proceedings initiated by the Assessing Officer were liable to be quashed on the ground that there was no tangible material before the Assessing Officer even though the assessment was completed originally u/s 143(1). - the initiation of reassessment proceedings by the Assessing Officer itself was bad in law and the reassessment completed in pursuance thereof is liable to be quashed being invalid. - Decided in favor of assessee.
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