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| The Tax Publishers2020 TaxPub(DT) 5359 (Ctk-Trib) INCOME TAX ACT, 1961
Section 147
Inadvertently deduction allowed under section 54F, could not be a ground to reopen the assessment, which was completed under section 143(3) and where it appeared from the order sheet that assessee had appeared time to time and produced the documents as directed by AO.
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Reassessment - Validity - No jurisdictional foundation -
Assessee's assessment was reopened under section 147 denying excess allowance of deduction claimed under section 54F. Held: The ground that inadvertently deduction was allowed under section 54F, could not be a ground to reopen the assessment, which was completed under section 143(3) and as it appeared from the order sheet, the assessee had appeared time to time and produced the documents as directed by AO. If there was any advertent mistake pointed out by AO, the same could have been rectified under section 154 and not reopening the assessment.
REFERRED :
FAVOUR : In favour of assessee.
A.Y. : 2012-13
IN THE ITAT, CUTTACK BENCH
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