Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (4) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (4) TMI 554 - AT - Income TaxReopening of assessment - reassessment as barred by limitation - Addition of undisclosed Foreign Asset - HELD THAT:- Hon’ble High Court in the case of Jayashree Jayakar Mohankar [2022 (7) TMI 1395 - CALCUTTA HIGH COURT] held that proceedings initiated by AO u/s 147/148 of the Act had become time barred prior to 01.07.2012 and which could not have been revived by Section 149(1)(c). CIT(A) has rightly decided the legal issue raised by the assessee in accordance to the ratio laid by the Hon’ble Delhi High Court in Brahma Datt Vs. ACIT [2018 (12) TMI 832 - DELHI HIGH COURT] which decision was challenged by the department before the Hon’ble Supreme Court without any success because SLP was dismissed [2019 (7) TMI 351 - SC ORDER]. Appeals filed by the revenue dismissed.
|