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2022 (11) TMI 846 - AT - Income TaxValidity of reopening for the assessment framed u/s 147 - Reason to believe - HELD THAT:- Admittedly, the AO on verification of the same set of documents which were available during the original proceedings formed reasons to believe that there is an escapement of income on account of excess remuneration allowed to the assessee. In view of the above, we hold that the proceedings initiated under section 147 of the Act are not sustainable and therefore liable to be quashed for the reasons discussed above. Hence, the assessee succeeds on technical count raised by it. See Fibers and Fabrics International (P.) Ltd. [2022 (4) TMI 1433 - SC ORDER] - Decided in favour of assessee.
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