Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2019 (8) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (8) TMI 1454 - AT - Income TaxReopening of assessment u/s 147 - non compliance to notice - as per Revenue there was no compliance on the part of the assessee to the notice issued by AO u/s 148 and there was not even any request made by the assessee in writing to treat the return of income originally filed as the return filed in response to notice issued u/s 148 - HELD THAT:- The notice u/s 148 dated 31.03.2017 thus was duly complied with by the assessee and this compliance was in accordance with law as held by the ld. CIT(Appeals) after discussing all the facts of the case and the relevant provisions of the law. D.R. in this regard has not raised any material contention to rebut or controvert the findings or reasons given by the ld. CIT(Appeals) to decide this issue in favour of the assessee. Moreover, it is observed that the reopening of assessment by the Assessing Officer was held to be bad-in-law by the ld. CIT(Appeals) on as many as three separate counts and the Revenue having challenged the same only on one count and not on other two counts, this appeal of the Revenue has become only academic. Keeping in view all these facts and circumstances of the case, we find no merit in the appeal of the Revenue and dismiss the same.
|