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2022 (10) TMI 623 - AT - Income TaxReopening of assessment u/s 147 - Notice beyond period of four years - whether any reasons recorded that there is failure on the part of the assessee to disclose fully and truly all material facts necessary for framing of assessment for the relevant assessment year? - HELD THAT:- We are of the view that the reopening is beyond 4 years and as the original assessment was framed u/s. 143(3) of the Act, the Revenue could not establish any failure on the part of the assessee to disclose fully and truly all material facts necessary for its assessment, the reopening in present case is bad in law and hence, quashed. Since we have quashed the reassessment on reopening, we need not to go into the merits of the case. Decided in favour of assessee.
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