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2018 (7) TMI 2202 - AT - Income TaxReopening of assessment u/s 147 - sufficiency of reasons - AO jurisdiction to proceed with the reassessment proceeding - HELD THAT:- The specific observations of the Jurisdictional High Court in case of CIT vs. Shri Ram Singh [2008 (5) TMI 200 - RAJASTHAN HIGH COURT] are that in case during the proceedings U/s 147 of the Act, the AO came to conclusion that any income chargeable to tax which according to the reasons to believe has escaped assessment for any assessment year, did not escape assessment, then, the mere fact, that the AO entertained a reason to believe though a genuine reasons to believe would not continue to vest him with the jurisdiction to tax any other income. In the case once the income which was proposed to assess as per reasons recorded by the AO found declared in the return of income then, the AO ceased to have jurisdiction to proceed with the reassessment proceeding to assess any other income to tax. In view of the above facts and circumstances of the case and by following in case of the CIT vs. Shri Ram Singh we hold that the reassessment is in valid and not sustainable in law. Accordingly, we quash the reopening of the assessment and consequential reassessment - Appeal filed by the assessee is allowed
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