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2017 (5) TMI 475 - AT - Income TaxReopening of assessment - reasons to believe - Held that:- The present case is one of change of opinion. Further, as regards the requirement of true and correct disclosure by the assessee, find that in the reasons recorded, the A.O has nowhere made any allegation on this count. Not even a whisper of any allegation that there has been a failure on the part of the assessee to disclose fully and truly all material particulars necessary for assessment. See Allied Strips Limited Versus Assistant Commissioner Of Income Tax Central Circle-15 [2016 (5) TMI 580 - DELHI HIGH COURT] - Decided in favour of assessee.
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