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| The Tax Publishers2020 TaxPub(DT) 0053 (Del-Trib) INCOME TAX ACT, 1961
Section 147, Proviso
AO reopened assessment on the basis of entries which were duly reflected in audited balance sheet and Profit and Loss Account being part of original assessment proceedings, accordingly, no failure could be alleged on the part of the assessee to make full and true disclosure of all material facts and reopening beyond four years was hit by proviso to section 147.
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Reassessment - Beyond four years - No failure to disclose fully and truly all material facts - Entries reflected in audited financial statement
AO initiated reassessment proceedings under section 147/148 after expiry of four years from the end of relevant assessment year and made disallowance on account of outstanding municipal tax liability of Rs. 11 crores by invoking section 43B. Held: AO reopened assessment on the basis of entries which were duly reflected in audited balance sheet and Profit and Loss Account being part of original assessment proceedings, accordingly, no failure could be alleged on the part of the assessee to make full and true disclosure of all material facts and reopening beyond four years was hit by proviso to section 147.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2006-07
INCOME TAX ACT, 1961
Section 43B
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