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2015 (8) TMI 411 - AT - Income TaxValidity of reopening of assessment - Held that:- Assessing Officer had issued notice after a period of four years, that in the reasons recorded by him he has not directly or indirectly mentioned that there was failure on the part of the assessee, that proviso to section 147 of the Act specifically mandates that issue of notice after a period of four years should be based on the failure of the assessee. As there was no failure by the assessee to disclose material facts truly and fully, therefore, the notice issued by the Assessing Officer under section 148 of the Act was not valid. See Commissioner of Income-tax, Guwahati - 1 Versus Sonitpur Solves Ltd. [2013 (4) TMI 422 - GAUHATI HIGH COURT ] - Decided in favour of assessee.
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