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2018 (6) TMI 1836 - ITAT DELHIReopening of assessment u/s 147 - Necessity of recording satisfaction by the AO as required prior issuing the notice u/s 147 - unexplained investment in share capital - HELD THAT:- AO himself was of the view that the amount so invested in share application money needs verification, despite that he has the reason to believe that the investment in share application money and extent of availability during the year 2006-07 (wrongly mentioned in the reasons recorded as “2006-06”) is from (wrongly mentioned in the reasons recorded as “form”) undisclosed sources which is escaped to tax, which is not sustainable in the eyes of law as laid down in the case of Sampatraj Dharmichand Jain [2016 (7) TMI 67 - GUJARAT HIGH COURT] wherein it has been observed that “reopening may not be permitted for mere verification purpose.” Appeal of the assessee is allowed.
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