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2014 (2) TMI 302 - AT - Income TaxReassessment proceedings u/s 147 of the Act quashed – Held that:- The assessment is beyond four years and there is no whisper in the reasons recorded for issuing notice u/s. 148 of the Act or in the reassessment order framed u/s. 147/148/143(3) of the Act dated 04.11.2011 that there is failure on the part of the assessee to disclose truly and fully all material facts necessary for assessment - the conditions of first proviso to section 147 of the Act are not fulfilled - subsequent to passing of the regular assessment in November 2006 no new material or information came in AO's possession consequent to which he could form his reason to believe that income chargeable to tax escaped assessment - neither in the recorded reasons nor even in the assessment order, the AO has even alleged that escapement of income was consequent upon appellant's failure to disclose truly and fully all material facts necessary for assessment – the conditions of the first proviso to sec. 147 were not fulfilled - There was no infirmity in the order of CIT(A) – thus, the order of the CIT(A) quashing the reassessment framed by AO u/s. 147 r.w.s. 148/143(3) of the Act upheld – Decided against Revenue.
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