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2020 (2) TMI 95 - HC - Income TaxReopening of assessment u/s 147 - issue of notice for reopening beyond the period of four years - HELD THAT:- There was no failure on the part of the assessee to disclose truly and fully all material facts necessary for assessment. We are of the view that the case on hand is one of change of opinion. There is hardly anything on record to indicate that there was failure on the part of the assessee to disclose truly and fully all material facts. There was no tangible material available for the purpose of issuing the notice for reopening beyond the period of four years. The impugned notice under Section 148 of the Act, 1961 is not sustainable in law. - Decided in favour of assessee.
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