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2015 (10) TMI 2829 - AT - Income TaxReopening of assessment u/s 147 - assessment Reopened after four years from the end of the relevant assessment year - eligibility of reasons to believe - HELD THAT:- Undisputedly in the instant case, nothing has been mentioned by the Assessing Officer that income chargeable to tax has escaped assessment on account of failure on the part of the assessee. Moreover, the issue on which assessment was reopened was already discussed by the AO in the original assessment. In the light of these facts, we are of the considered view that the assessment was reopened without the jurisdictional foundation u/s 147 of the Act. Therefore, the notice u/s 148 and subsequent proceedings are without jurisdiction and liable to be quashed - Decided against revenue.
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