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| The Tax Publishers2020 TaxPub(DT) 0472 (Del-Trib) : (2020) 077 ITR (Trib) 0694 INCOME TAX ACT, 1961
Section 147
Since AO did not specify as to in which manner there was failure on the part of assessee to disclose fully and truly all material facts necessary for his assessment for relevant assessment year, therefore, proviso to Section 147 would apply in favour of assessee.
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Reassessment - Full and ture disclosure - Notice issued after expiry of four years -
Assessee challenged reopening of assessment under section 147 contending that notice was issued after four years from end of relevant assessment year. Held: There was no failure on part of assessee to disclose all primary facts. AO did not specify as to in which manner there was failure on the part of assessee to disclose fully and truly all material facts necessary for his assessment for relevant assessment year. Therefore, proviso to Section 147 would apply in favour of the assessee.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
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