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2018 (11) TMI 1175 - HC - Income TaxRe-assessment proceedings u/s 147 - reopening of after four years of completion of the assessments - rectification proceedings u/s 154 which is handed over across the Bar for the respondent - Held that:- It is pertinent that even in the rectification order, AO specifically notices that the assessee had been maintaining accounts for income tax purposes under the cash system. There was no accounts called for by the AO, who completed the assessment proceedings. We are of the opinion that there could be no allegation raised of non-disclosure of full and true material facts. The reassessment proceedings having been attempted after a period of four years as prescribed under Section 147, there should be non-disclosure of full and true material facts. We agree with the Tribunal that there was no warrant for re-assessment especially after the expiry of four years. We reject the I.T.Appeals, answering the questions of law in favour of the assessee
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