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2014 (5) TMI 1169 - AT - Income TaxReopening of assessment proceedings u/s 147 - bogus share capital receipt - non independent application of mind by AO - borrowed knowledge - Held that:- The reason recorded by the Assessing Officer were merely on the basis of information received from DDIT (Inv.) Udaipur and Mumbai, therefore, from the so called reason, it was not at all discernable as to whether the Assessing Officer had applied his mind to the information and independently arrived at a belief that on the basis of the material which he had before him the income had escaped assessment, therefore, the reassessment u/s 147 of the Act was not valid and accordingly the same is quashed. - Decided in favour of assessee
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