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2023 (10) TMI 264 - AT - Income TaxReopening of assessment u/s 147 - reason to believe - notice beyond four years - HELD THAT:- As in the absence of anything in the reasons recorded to suggest that the income chargeable to tax which has escaped assessment i.e. one lakh rupees or more, the notice issued u/s 148 of the act beyond four years of the end of the relevant Assessment Year, is treated as invalid, therefore, in our considered opinion, the said ratio is applicable to the present case in to-to and the Ld. CIT(A) erred in upholding the validity of the assessment order, accordingly, we allow Ground No. 1 & 2 of the assessee by setting aside the orders of the Lower Authorities.
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