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2022 (2) TMI 482 - AT - Income TaxReopening of assessment u/s 147 - reopening was beyond 4 years - unabsorbed depreciation disallowed - HELD THAT:- As gone through the reasons recorded as well as original assessment order. We noted that the reasons for reopening and the issue examined by the AO in original assessment proceedings are exactly the same. There is no difference. As we have already extracted the reasons recorded as well as the finding of the AO in original assessment proceedings, we could not point out what is the failure of the assessee to disclose fully and truly the material facts for completion of assessment of the assessee. Even on merits the CIT(A) has categorically held that the assessee is eligible for carry forward of depreciation for the assessment year 2002-03 to 2004-05. - Decided against revenue.
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