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2015 (7) TMI 1394 - AT - Income TaxReopening of assessment u/s 147 - protective addition - HELD THAT:- Revenue has not initiated any substantive assessment or no addition has been made on substantive basis in any other hand, there is no question of any protective assessment in the present case from the reasons recorded by the AO as reproduced herein above. We are of the view that the AO has initiated re-assessment proceedings u/s 147/148 of the Act on the basis of the statement of one of the directors of the assessee company that the transactions in the hands of the other parties are not accounted for and this may be the income of the assessee. The revenue could not bring on record anything against the other parties or who are the other parties against whom substantive addition is to be made. There is no substantive addition made in any of the hand till date as conceded by the ld. Sr.DR before us now. In view of the above we are very clear that the re-assessment proceedings initiated u/s 147/148 of the Act is invalid and hence quashed. - Decided in favour of assessee.
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