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2020 (2) TMI 1338 - AT - Income TaxValidity of reopening of assessment u/s 147 - eligibility of reasons to believe - reopening after four years - HELD THAT:- The assessment for the assessment year 1989-90 was completed u/s. 143(3) on 29.06.2011. In such case, after the expiry of 4 years from the end of the relevant assessment year, the AO can proceed to reassess the income only when he records the reason of failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment in that assessment year. In this case, the material on which the Assessing Officer reopened were filed by the assessee was very well considered by the AO. Therefore, the notice issued u/s. 147 does not satisfy the legal condition laid in first proviso to section 147 - Decided in favour of assessee.
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