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2022 (3) TMI 306 - HC - Income TaxReopening of assessment u/s 147 - Eligibility of reasons to believe - HELD THAT:- The reason to believe is invalid and has no rational nexus to the belief for escapement of income and there was no fresh material on record to initiate re-assessment proceedings. This Court is further of the view that no useful purpose would be served by giving an opportunity to file a counter affidavit. Accordingly, the said request of learned counsel for the respondent is declined and the impugned notice dated 28th March, 2021 and the order disposing objections dated 27th December, 2021 are quashed.
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