2024 (2) TMI 1346 - SCH - Income Tax

Reopening of assessment u/s 147 - transactions in question were in the nature of partners capital withdrawal - subjective satisfaction and reasons to believe that the income had escaped the assessment - as decided by HC 2022 (12) TMI 1281 - GUJARAT HIGH COURT communication whereby the reasons recorded were supplied no satisfaction was recorded by the assessing officer that the income chargeable to tax has escaped assessment. Not only the said requirement was not satisfied but there was no actual escapment of income as well - HELD THAT - We are not inclined to interfere with the impugned judgment passed by the High Court. Hence the Special Leave Petition is dismissed.

Summary

The Supreme Court dismissed the Special Leave Petition and did not interfere with the impugned judgment passed by the High Court. Delay was condoned, and pending applications were disposed of.