Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2014 (12) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (12) TMI 607 - ALLAHABAD HIGH COURTValidity of notice for reopening of assessment u/s 148 – Held that:- The assessment is sought to be re-opened beyond a period of 4 years of the relevant AY - the material which was impounded during the course of the survey operation u/s 133-A was after the order of assessment was passed - This furnished a valid basis to reopen the assessment u/s 148 - it cannot be said that the reasons, on the basis of which re-assessment is sought, constitute a mere change of opinion - There was, indeed, a failure on the part of the assessee to fully and truly disclose all material facts necessary for the assessment – thus, the jurisdictional requirement for reopening the assessment has been duly fulfilled – the order of the Tribunal is upheld – Decided against assessee.
|