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2014 (8) TMI 761 - ITAT DELHIReopening of assessment u/s 147/148 – No application of mind - Held that:- Following the decision in Commissioner of Income Tax - III Versus M/s Suren International Pvt. Ltd. [2013 (5) TMI 414 - DELHI HIGH COURT] - the AO except preparing the table of accommodation entries from the details claimed to have been received from the Investigation Wing, has not at all applied his mind - assessee rightly contended that there was no failure on the part of the assessee to disclose all material facts because in the documents attached to the return of income, all primary facts were disclosed - the contention of the assessee is that the AO issued the notice u/s 148 mechanically simply on the basis of information alleged to have been received from the Investigation Wing without application of mind - the reasons recorded without any application of mind cannot be said to be a proper belief with regard to escapement of income – the order of the CIT(A) is upheld – Decided against Revenue.
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