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2013 (3) TMI 245 - HC - Income TaxReopening of assessment - disallowance u/s 36 & 37 - Held that:- The provisions of Section 147 clearly prescribe that if the Assessing Officer has reason to believe that income chargeable to tax has escaped assessment, he can initiate proceeding. So, at present, only proceeding has been initiated. Prima facie,it cannot be said that the notice is without jurisdiction. The petitioner is at liberty to participate in the proceeding. The petitioner has already participated in the proceeding and tomorrow is the date of hearing. In such circumstances, it would not be just and proper to entertain the petition at this stage. It is hereby dismissed.
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