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2019 (10) TMI 1311 - HC - Income TaxReopening of assessment u/s 147 - Notice issued beyond a period of four years from the end of the relevant Assessment Year - HELD THAT:- It is the Petitioner’s case that the facts which forms the basis of reasons to believe the income chargeable to tax were completely disclosed. Moreover, it was also subject matter of consideration during the regular Assessment Proceedings. Thus, it is clear case of change of opinion. Therefore, without jurisdiction. As none appears for the Respondent, Registry is directed to issue a notice to the Respondent, returnable on 27th November, 2019. Humdust permitted.
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