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| The Tax Publishers2021 TaxPub(DT) 3398 (Hyd-Trib) INCOME TAX ACT, 1961
Section 147
AO had nowhere recorded any reasons to believe that assessee had not truly and fully disclosed details of her taxable income. Accordingly, reopening of assessment beyond four years was hit by proviso to section 147 and was, therefore, set aside.
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Reassessment - Beyond four years - No failure to disclose fully and truly all material facts -
AO received information from ACB as to assessee being beneficairy of accommodation entry providers. Accordingly, AO reopened assessment after expiry of four years from the end of relevant assessment year. Assessee took plea of proviso to section 147. Held: It was evident from perusal of reasons recorded in assessee's case that AO had nowhere recorded any reasons to believe that assessee had not truly and fully disclosed details of her taxable income. Accordingly, reopening of assessment beyond four years was hit by proviso to section 147 and was, therefore, set aside.
Relied:Hindustan Lever Ltd. v. R.B. Wadkar (2004) 268 ITR 332 (Bom-HC) : 2004 TaxPub(DT) 1424 (Bom-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2007-08 to 2009-10
INCOME TAX ACT, 1961
Section 68
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