2018 (6) TMI 1683

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..... he Revenue is as to the extent of rectification permissible under Section 154 of the Income Tax Act, 1961. The assessment in the case was completed under Section 143 (3) of the Act on March 29, 2006. The Assessing Officer sought to rectify the order of assessment on the ground that the assessee did not show any long-term capital gains in the return of income for the relevant assessment year of 2 .....

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..... n similar lines. Since both appellate authorities below found, as a matter of fact, that the Assessing Officer could not have reopened the matter on the basis that long-term capital gains had not been disclosed by the assessee, the order impugned herein does not call for any interference. The appellate authorities below were perfectly justified in holding that the issue as to capital gains was a .....

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