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2017 (6) TMI 555 - GUJARAT HIGH COURTReopening of assessment - excess deduction by the Assessing Officer during the original assessment and non disallowance of expenditure paid to a foreign company without deducting tax at source - Held that:- With respect to the first ground, the Assessing Officer himself in the reasons had recorded that it was on verification of records that the said ground that they imparted, clearly eliminating any possibility of the assessee having not disclosed true facts. Perusal of the reasons would further show that if at all it was an error of the Assessing Officer to have granted larger relief than what was available to the assessee. On the second ground of payment without deducting tax at source, there is nothing to suggest that there was any failure on the part of the assessee to disclose truly and fully all material facts. - Decided in favour of assessee.
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