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2018 (2) TMI 977 - AT - Income TaxReopening of assessment - three items of income have escaped assessment - validity of reasons to believe - Held that:- A perusal of the reasons to believe reveals that the records on the basis of reasons for re-opening were recorded were available before the AO even at the time of original assessment proceedings as is apparent from the statement of computation of total income placed at page 1 of the paper book and also fortified by the discussions by the AO himself in the original assessment order passed under Section 143(3) r.w.s. 153A dated 22.12.2008 of the original assessment order. Thus we find that the AO has recorded the reasons on re-examination of the same records/information which were available at the time of framing the original assessment passed under Section 143(3) r.w.s. 153A of the Act. A review by the AO of his own order is not permissible under the Act as decided by the Hon'ble Supreme Court in the case of Kelvinator of India Ltd. (2010 (1) TMI 11 - SUPREME COURT OF INDIA ) - Decided in favour of assessee
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