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2023 (4) TMI 63 - ITAT BANGALOREValidity of reopening of assessment - Reason to believe - as argued reasons recorded for issuance of notice u/s 148 there is no allegation that the assessee had not disclosed fully and truly all material facts necessary for assessment - HELD THAT:- We do not find anywhere in the copy of reasons recorded that there is any allegation upon the assessee regarding not disclosing fully and truly all material facts for completion of assessment which is necessary in the case of reopening beyond the period of 4 years in the case of assessment completed u/s 143(3). Since the case relates to AY 1995-96 and the notice has been issued by the AO on 30.07.2001, we observe from the notice that necessary ingredients, which were required to be mentioned for reopening beyond the period of 4 years has not been mentioned - we uphold that the reasons recorded by the AO for exercising jurisdiction under Section 147 is not in conformity with the provisions of Section 147 - we allow ground raised by the assessee.
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