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2010 (12) TMI 736 - PUNJAB AND HARYANA HIGH COURT
Validity of reassessment - Deduction u/s 80HHC - Addition u/s 14A - Income escaping assessment - Mere change of opinion and no new material has come to light after framing of original assessment under Section 143(3) of the Act were the other grounds of challenge to the reassessment proceedings - whether in view of Explanation 1 to Section 147 of the Act, could the mere production of documents and other evidence before the Assessing Officer during the regular assessment proceedings, amount to true and full disclosure within the meaning of Section 147 of the Act - Once it is held that mere production of account books and the documents where from the Assessing Officer could have gathered the details of escaped income, would not amount to true and full disclosure within the meaning of Section 147 of the Act, necessarily, it is to be held that the action taken by the Assessing Officer beyond 4 years shall be within limitation - Nothing could be pointed out with reference to the original assessment order that the assessing authority had specifically dealt with these issues at the time of framing original assessment - Decided against the assessee