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2013 (7) TMI 446 - HC - Income TaxReopening of assessment - whether the proceedings u/s 147 can be justified beyond a period of four years with reference to any act or omission on the part of the assessee in effecting the true and full disclosure - Held that:- the course and proceedings pursued by the third respondent are in conformity with the statutory prescription and there is no violation of any legal provisions or binding judicial precedents - no opinion was expressed by the respondent thus it cannot be said that section 147 proceedings have been initiated by change of opinion/by way of review - In any view of the matter, it is more a question of fact and the true state of affairs can be brought to light only on furnishing the export turnover details sought for from the part of the third respondent and the actual fact has to be established by the assesse – petition decided against the assesse.
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