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2022 (11) TMI 977 - AT - Income TaxReopening of assessment u/s 147 - Reasons to believe - notice beyond period period of four years - HELD THAT:- Once the factual position is clear and admittedly, the assessment year involved is 2013-14 and notice u/s.148 of the Act was issued on 22.03.2019, which is beyond 4 years from the end of the relevant year and there is no failure on the part of the assessee to disclose fully and truly all material facts necessary for its assessment for the relevant assessment year, the issue is squarely covered in favour of the assessee by the decision of Foramer France,[2003 (1) TMI 101 - SC ORDER]. In view of the above, we find no infirmity in the order of CIT(A) and hence, we confirm the order of CIT(A) quashing the reassessment. Appeal filed by the Revenue is dismissed.
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