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2018 (3) TMI 956 - AT - Income TaxReassessment order passed u/s.147 - validity of reasons to believe - independent application of mind by AO - Held that:- Assessing Officer has initiated reassessment proceedings on the same facts which were available before him at the time of making assessment u/s.143(3) of the Act and no new tangible material has come on the basis of which it could be said that the Assessing Officer has reason to believe that income chargeable to tax has escaped assessment on account of failure on the part of the assessee to disclose truly and fully material of facts in the assessment. Assessing Officer has not brought on record any new tangible material to initiate reassessment proceedings but relied only on tax audit report and financial statements, which were already filed before the Assessing Officer in the scrutiny proceedings. Thus we are inclined to set aside the order of the CIT(A) on this ground and quash the reassessment order. - Decided in favour of assessee
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