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2020 (2) TMI 1354 - AT - Income TaxReopening of assessment u/s 147 - valid reason to believe - HELD THAT:- Reasons recorded by the AO are replied by the assessee in response to notice u/s. 148 and rebutted that the admission of ₹ 7,00,000/- during the course of survey and submitted that he has not made any excess investment of ₹ 7,00,000/- and other queries are also replied. No tangible materials before the AO for reopening the assessment u/s.147 . As regards to the contention of Ld. D.R. that there was audit objection, as perused the assessment records and find that there is no such mention of audit objection in the satisfaction note. In the absence of any fresh material, the reappraisal of same material to initiate reassessment proceedings tantamounts to change of opinion and hence bad in law - Reassessment proceedings and first appellate order are dismissed. - Decided in favour of assessee.
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