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2010 (9) TMI 197 - HC - Income TaxCondonation of delay in re-filing the appeal - Held that: - no action can be taken under Section 147 of the Act, 1961 after expiry of four years from the end of the relevant Assessment Year unless two conditions are simultaneously fulfilled - firstly, the AO must have reasons to believe the income chargeable to tax has escaped assessment - secondly, the AO must have reasons to believe that such escapement occurred either due to omission or failure on the part of the respondent-assessee to disclose fully and truly all material facts necessary for its assessment - AO has failed to prove and establish that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment - Appeal is dismissed
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