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2015 (11) TMI 1838 - ITAT AHMEDABADReopening of assessment u/s 148 - HELD THAT:- In the cases where assessments are being reopened after the end of four years from the end of relevant assessment year, and where original assessment is completed under section 143(3), it is sin qua non that the Assessing Officer demonstrates that there was failure on the part of the assessee to disclose all the related material facts. No such exercise has been carried out on the facts of the present case. In the reasons recorded by the Assessing Officer it is not even his case that any material facts were withheld by the assessee. In this view of the matter, we quash the reassessment proceedings. The assessee gets the relief accordingly.
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