Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2010 (1) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2010 (1) TMI 75 - HC - Income TaxReopening of assessment by issue of notice under section 148 - While the question as to whether a declaration filed by the assessee under the voluntary disclosure scheme can constitute information for the purpose of reopening under section 147 may be a debatable point and either way may be the position, it is not open for this court to consider the matter now, as the Tribunal has recorded a finding that there was no application of mind on the part of the assessing authority for reopening, particularly, if on perusing the actual reasoning as recorded in the proposition for reopening, which we have already extracted above. We are in full agreement with this view that the assessing authority cannot act on the dictates of the Commissioner, who had directed him to reopen the concluded assessment
|