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2023 (2) TMI 1173 - DELHI HIGH COURTValidity of reopening of assessment u/s 147 - substantial question of law - HELD THAT:- As both counsels agree, that the following questions of law would arise for consideration: (i) Whether the Tribunal erred in admitting and adjudicating the additional ground concerning jurisdictional defect, in the reasons recorded by the AO, even when no such ground was raised before the first appellate authority CIT(A)? (ii) Whether the Tribunal misdirected itself in law in holding that the reasons recorded by the Assessing Officer for triggering proceedings under Section 147/148 of the Income Tax Act, 1961 were vague, bereft of reasons and did not establish a live link between the material available with him and formation of belief that income chargeable to tax had escaped assessment? Arguments heard. Judgment reserved.
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