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| The Tax Publishers2020 TaxPub(DT) 4488 (Mum-Trib) INCOME TAX ACT, 1961
Section 147
Original return filed by assessee was not subjected to scrutiny assessment. It was quite discernible that AO was clinched with specific tangible information as to possible escapement of income and case was duly reopened within 4 years from end of relevant assessment year as per due process of law by issuance of statuary notices under section 148 as well under section 143(2) and 142(1). Nothing more, was required at this stage to reopen assessment proceedings. Therefore, reopening was valid.
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Reassessment - Validity - Information emanated from Investigation Wing - Original return not subjected to scrutiny assessment
AO received information from investigation wing as to assessee being beneficiary of providers of bogus purchase bills. Accordingly, AO reopened assessment by issuing notice under section 148. Assessee's case was that reassesment proceedings could not be initiated merely on the basis of inforamtion received from investigation wing. Held: Original return filed by assessee was not subjected to scrutiny assessment. It was quite discernible that AO was clinched with specific tangible information as to possible escapement of income and case was duly reopened within 4 years from end of relevant assessment year as per due process of law by issuance of statuary notices under section 148 as well under section 143(2) and 142(1). Nothing more, was required at this stage to reopen assessment proceedings. Therefore, reopening was valid.
REFERRED :
FAVOUR : Against the assessee.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 69C
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