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2022 (11) TMI 1250 - ITAT HYDERABADReopening of assessment u/s 147 - reason to believe - tangible material before the AO - additional income offered to the closing stock - assessee has increased the opening stock to the extent of the disclosure made during the course of survey operation - HELD THAT:- As in absence of any tangible material before the AO, he could not have reopened the assessment for the impugned assessment year. In our opinion, mistake, if any has been committed by the assessee in AY 2009-10 and the AO was also aware of the same. Therefore, instead of reopening the assessment for AY 2009-10, AO could not have reopened the assessment for AY 2010-11. We quash the reassessment proceedings and the grounds raised by the assessee on this issue are allowed.
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