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2019 (12) TMI 608 - ITAT CHENNAIReopening of assessment u/s 147 - notice u/s.148 issued after four years from the end of the relevant Assessment Year - HELD THAT:- AO has not recorded any failure on the part of the assessee to disclose fully and truly all material facts necessary for its assessment for that assessment year. Therefore, the assessee clearly makes out the case. Since the essential condition for reopening the assessment u/s.147 is absent, the reassessment made u/s.147 w.r.s143(3) dated 30.03.2016 is not valid and hence the re-assessment order is quashed and the cross objection filed by the assessee is allowed. Since we have quashed the reassessment order passed u/s.143(3) r.w.s147, the appeal filed by the Revenue has become infructuous and hence dismissed.
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