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2021 (6) TMI 499 - AT - Income TaxReopening of assessment u/s 147 - Assessing Officer had contested the Revenue’s audit objection allegedly pointing out escapement of assessee’s taxable income which in turn was also approved by the Pr.CIT having jurisdiction - HELD THAT:- The Revenue is fair enough in not denying all these clinching aspects in its pleadings. We thus conclude that the Revenue’s audit authorities’ objection pitted against the Assessing Officer’s opinion having jurisdiction regarding initiation of the impugned re-opening mechanism who duly concluded that no income had escaped assessment; must make way for the latter’s opinion only. We accordingly uphold the CIT(A)’s impugned conclusion quashing the impugned re-opening for this precise reason alone. Revenue’s sole substantive ground fail.
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