INCOME TAX ACT, 1961

Section 147

Reassessment - Change of opinion - Denial of deduction claimed by assessee under section 80-IB(4) -

AO sought to reopen the assessment on the ground that assessee had not furnished a separate Profit and Loss Account and Balance Sheet of eligible business exhibiting the actual amount of profit of eligible business and hence, it was not eligible for deduction under section 80-IB(4). Held: It was submitted that at the time of scrutiny assessment, AO had gone into the issue threadbare and hence, it was evident that Revenue sought to reopen the assessment on a mere change of opinion. Assessment was sought to be reopened beyond a period of four years from the end of the relevant assessment year and that, in the absence of any failure on the part of assessee to fully and truly disclose all the material facts, assumption of jurisdiction by AO under section 147 was without authority of law. Issue Notice, returnable on 10-12-2019. By way of ad-interim relief, further proceedings pursuant to notice issued under section 148 was stayed.

REFERRED :

FAVOUR : Returnable notice issued

A.Y. :

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