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2013 (11) TMI 1511 - ITAT COCHINValidity of reassessment u/s 147 - Without recording the reasons for reopening - Held that:- The AO has not showed that escapement of income is on account of failure on the part of the assessee to fully and truly disclose all material facts necessary for assessment - The assessment year involved is A.Y. 2004-05 and impugned notice u/s. 148 was issue on 23.3.2011 i.e. after expiry of about 4 years from the end of the said assessment year - Following Sound Casting Pvt. Ltd. Vs. DCIT [2012 (4) TMI 248 - BOMBAY HIGH COURT] - The AO has failed to establish that there was failure on the part of the assessee to disclose fully and truly all the material facts necessary for assessment - Decided against Revenue.
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