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2022 (3) TMI 1039 - HC - Income TaxReopening of assessment u/s 147 - deduction u/s 80IA - HELD THAT:- Proceeding under Section 148 were not issued based on revenue audit objection, hence, the appeal filed by the appellant before the ITAT has rightly been dismissed under the CBDT circular No. 03/2018 dated 11.07.2018. The first appellate authority has also held that aforesaid notice u/s 148 was issued on 03.03.2014 i.e. after four years from the end of the assessment year 2007 – 08. This notice nowhere says that it is issued based on revenue audit objection, hence, this case does not fall under exception 10(c) of Circular No.03/2018 dated 11.07.2018. ITAT has not committed any error of law by dismissing the MA filed for recalling of the consolidated order dated 22.08.2019 disposed of relying on circular No. 03/2018 dated 11.07.2018
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