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2020 (7) TMI 440 - HC - Income TaxReopening of assessment u/s 147 - change of opinion - expenses incurred on the cost of construction of building on the lease hold building/land - HELD THAT:- Respondent - assessee filed computation statement along with the original assessment, which showed the expenditure on construction of building on lease hold land/building and this was specifically mentioned and claimed as a revenue expenditure. The assessment was completed after examining the computation statement and break-up details furnished by the assessee. After taking into consideration these facts and the fact that the assessment was reopened beyond a period of four years and also after considering the Proviso to Section 147 Tribunal held that the reopening was one of change of opinion. The First Appellate Authority and the Tribunal, on facts, found that the respondent – assessee made a full disclosure of the expenditure and claimed the same as a revenue expenditure. We hold that no substantial question of law arises.
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