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2023 (2) TMI 499 - AT - Income TaxReopening of assessment u/s 147 - Reasons to belive - case can be reopened after expiry of four years from the end of the relevant Assessment Year - HELD THAT:- We have perused the reasons recorded u/s 148(2) of the Act and find that nowhere the Assessing Officer has stated that there is failure on the part of the assessee to disclose any material fact. It is apparent from the reasons that there is no satisfaction or mention of any failure on the part of the assessee. Therefore, on this count itself, the order passed by the Assessing Officer u/s 147/143(3) of the Act is liable to be quashed as the same is nullity in the eyes of law - Decided in favour of assessee.
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