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2022 (4) TMI 1500 - AT - Income TaxValidity of reopening of assessment u/s 147 - Reason to believe - HELD THAT:- The original assessment in this case was completed u/s 143(3) and the assessment year involved in A.Y. 2011-12. we find the AO in the instant case initiated reassessment proceedings by recording reasons on 29.03.2018. A perusal of the reasons clearly shows that there is absolutely no allegation whatsoever by the AO of any failure on the part of the assessee to disclose fully and truly all material facts necessary for completion of assessment. Reassessment proceedings initiated by the AO and upheld by the ld. CIT(A) are not in accordance with law. Decided in favour of assessee.
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