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2016 (5) TMI 1159 - ITAT PUNEReopening of assessment - delayed payment of PF and claim of deduction u/s.80IB without furnishing the full certificate of Form 10CCB along with return of income - Held that:- Since admittedly in the instant case the notice u/s.148 has been issued beyond a period of 4 years from the end of the relevant assessment year and there is no allegation by the AO in the reasons recorded for such reopening that there is any failure on the part of the assessee to disclose fully and truly all material facts necessary for completion of the assessment, therefore, following the decision of the Tribunal in assessee’s own case for A.Y. 2005-06 we hold that the notice issued by the AO u/s.148 in the instant case is void ab-initio. The grounds raised by the assessee on the issue of validity of reopening is thus decided in favour of the assessee.
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