The Tax Publishers2020 TaxPub(DT) 0971 (Ahd-Trib)

INCOME TAX ACT, 1961

Section 147

As, AO after receiving information verified balance sheet of assessee wherein impugned investment was shown, thus, AO after receiving information applied his mind by referring balance sheet of assessee and after that recorded his satisfaction under section 147 and thus allegation of assessee that there was change of opinion was not sustainable.

Reassessment - Reason to believe - no change of opinion on AO's part as alleged by assessee -

AO received information as to assessee having undisclosed investment in shares. Accordingly, AO reopneed assessment and made addition. Assessee alleged change of opinion of on AO's part.Held: As apparent, AO after receiving information verified balance sheet of assessee wherein impugned investment was shown. thus, AO after receiving information applied his mind by refgerring balance sheet of assessee and after that recorded his satisfaction under section 147 and thus allegation of assessee that there was change of opinion was not sustainable.

REFERRED :

FAVOUR : Against the assessee.

A.Y. : 2006-2007


INCOME TAX ACT, 1961

Section 69

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