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2013 (10) TMI 109 - HC - Income TaxProceeding u/s 158BD of the Income Tax Act – Held that:- In order to proceed against the firm, the AO should have recorded reasons, for issuing notice under Section 158 BD and having not recorded such reason, he could not be permitted to proceed with the assessment for the block period. Application of section 158BA(3) of the Income Tax Act - Undisclosed income of the assessee – Held that:- AO has tried to make out a case of undisclosed income on presumptions and discrepancies – A.O. failed to satisfy the requirement of the definition of the undisclosed income as provided under Section 158 B(b) of the Act - Assessee was squarely covered by Section 158 BA (3) of the Act and the CBDT Circular no. 717 - Decided against the revenue.
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