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2012 (2) TMI 281 - BOMBAY HIGH COURTValidity of reopening of assessment previously framed after scrutiny beyond 4 years from the end of relevant A.Y – A.Y. 04-05 sought to be reopened on the basis of an order of assessement for A.Y. 06-07 – A.O. did not specifically deal with the eligibility to claim a deduction u/s 10A – Held that:-The order for A.Y. 2006-07 is based on disclosures made by the assessee during the course of assessment proceedings for that year and it is not the submission of the assessee before this Court that the same disclosures were also made during the course of A.Y. 2004-05. In the circumstances, we are of the view that though the reopening of the assessment in the present case has taken place beyond a period of four years, the jurisdictional condition for reopening the assessment u/s 147 has been fulfilled – Decided against the assessee.
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