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2019 (8) TMI 985 - ITAT PUNEReopening of assessment u/s 148 - validity of reasons to believe - HELD THAT:- AO has reopened assessment beyond the period of four years from the end of relevant assessment year. AO has power to reopen the assessment after the expiry of four years from the end of relevant assessment year if, the income has escaped assessment by reason of failure on the part of assessee to disclose fully and truly all material facts necessary for the assessment for that assessment year. In the instant case, we observe that reassessment proceedings have been initiated by the Assessing Officer on reappreciation of facts and documents already on record. In the instant case, we find that the AO has resorted to provisions of section 148/147 merely on change of opinion after reappreciation of facts that were available before him in proceedings u/s. 143(3) of the Act. We find no reason to interfere with the well reasoned findings of First Appellate Authority. Accordingly, the impugned order is upheld and the appeal of Revenue is dismissed sans merits. reappreciation of facts that were available before him in proceedings u/s. 143(3) of the Act. We find no reason to interfere with the well reasoned findings of First Appellate Authority. Accordingly, the impugned order is upheld and the appeal of Revenue is dismissed sans merits.
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