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2020 (4) TMI 527 - AT - Income TaxReopening of assessment - absence of any reason to believe that income had escaped assessment - no sufficient opportunity to the assessee for representing his case - HELD THAT:- A.O. has not given sufficient opportunity to the assessee for representing his case. There is a lack of enquiry by the A.O. Even in the remand report, the A.O. has not made any enquiry from the subscriber companies. Assessee has brought to our notice that there are two assessment orders of the same date. No satisfactory reply is furnished by the A.O. There is no substantial difference between the assessment orders. One of the assessment order is having office note. Therefore, action of the A.O. regarding not making enquiries on the material and also not providing sufficient opportunity to the assessee, we set aside the assessment order and restore the assessment to the file of the A.O to dispose of the objections made against the reasons for reopening by way of a separate speaking order. - Decided in favour of assessee for statistical purposes.
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