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2023 (8) TMI 87 - HC - Income TaxReopening of assessment u/s 147 - Reason to believe - as argued reasons assigned by AO does not contain a whisper as regards the failure to disclose fully and truly all material facts - HELD THAT:- In light of the contention made on behalf of the petitioner that the material facts towards the sub-contract charges being a part of the record, it cannot be stated that there is failure of disclosure of material facts fully and truly, such factual assertion made is not controverted to by the other side. Accordingly, on the sole ground that there is absence of finding that there is failure on the part of the assessee to disclose fully and truly all material facts, which is a jurisdictional requirement, the notice issued u/s 148 of the Act is set aside.
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