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| The Tax Publishers2020 TaxPub(DT) 0376 (SC) INCOME TAX ACT, 1961
Section 261 Section 147
Where the Department preferred SLP to appeal against the judgment of Delhi High Court in Revolution Forever Marketing (P) Ltd. v. ITO [W.P.(C) No. 10857/2016, dt. 14-2-2019] : (2019) 413 ITR 400 (Del) : 2019 TaxPub(DT) 3668 (Del-HC), whereby the High Court held that in the present case, no such inquiry was made, that the failure of AO in that regard did not clothe it with the power to carry out reassessment under section 147/148 and also, the principal basis for reassessment appeared to be the opinion of the Revenue that substantial cash transactions were carried out, having regard to the date of opening of the accounts, which were not verified, therefore, reassessment under section 147 was invalid, the Supreme Court dismissed the SLP.
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Appeal (Supreme Court) - Special leave petition - Reassessment - Validity --Absence of fresh material
Department preferred SLP to appeal against the judgment of Delhi High Court in Revolution Forever Marketing (P) Ltd. v. ITO [W.P.(C) No. 10857/2016, dt. 14-2-2019] : (2019) 413 ITR 400 (Del) : 2019 TaxPub(DT) 3668 (Del-HC), whereby the High Court held that In the present case, no such inquiry was made, that the failure of AO in that regard did not clothe it with the power to carry out reassessment under section 147/148 and also, the principal basis for reassessment appeared to be the opinion of the Revenue that substantial cash transactions were carried out, having regard to the date of opening of the accounts, which were not verified, therefore, reassessment under section 147 was invalid. Held: The Supreme Court dismissed the SLP.
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