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| The Tax Publishers2019 TaxPub(DT) 0247 (Cal-HC) INCOME TAX ACT, 1961
Section 147
Where department was doubting deposit of TDS amount with government, it was imperative that such issue was looked into under provisions of sections 147 and 148.
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Reassessment - Full and true disclosure - Deposit of TDS with government -
AO issued notice to assessee under section 148 for reason that TDS certificates on which assessee relied upon were invalid and had no legal standing. In fact, it was doubted as to whether amounts covered under TDS certificates were deposited with the government or not.Held: Department was doubting the deposit of TDS amount with government. It was, therefore, imperative that such issue was looked into under provisions of sections 147 and 148. In the facts of the case, therefore, the authorities had not acted beyond jurisdiction in invoking the provisions of sections 147 and 148.
Relied:Phool Chand Bajrang Lal & Anr. v. ITO & Anr. (1993) 203 ITR 456 (SC) : 1993 TaxPub(DT) 1453 (SC).
REFERRED :
FAVOUR : Against assessee.
A.Y. :
IN THE CALCUTTA HIGH COURT
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