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2014 (11) TMI 56 - HC - Income TaxBasis for reopening of assessment u/s 147 – Power of the AO to make additions during reassessment - Income chargeable to tax came to notice subsequently in the course of proceedings u/s 147 – Held that:- In Majinder Singh Kang Versus Commissioner of Income-tax [2012 (6) TMI 616 - Punjab and Haryana High Court] considering the scope of Explanation 3 to section 147 of the Act it has been held that the AO is empowered to make additions even on the ground on which reassessment notice might not have been issued where during the reassessment proceedings, some other income has escaped assessment which comes to his notice during the course of the proceedings for reassessment u/s 148 of the Act - The provision nowhere postulates or contemplates that the AO cannot make any additions on any other ground unless some addition is made on the ground on which reassessment had been initiated – the decision in CIT v. Shri Ram Singh [2008 (5) TMI 200 - RAJASTHAN HIGH COURT] is distinguished as being decided prior to the insertion of Explanation 3 to section 147 of the Act - thus, the order of the Tribunal is set aside – Decided in favour of Revenue.
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