2024 (3) TMI 255 - SCH - Income Tax

Reopening of assessment u/s 147 - Reason to believe - admissibility of deduction u/s 80IA - as decided by HC 2023 (8) TMI 724 - PUNJAB AND HARYANA HIGH COURT jurisdictional condition precedent as laid down by the proviso to Section 147 i.e. failure to disclose material fact, which was proximate cause of escapement of income, has not been fulfilled at all in the present case - HELD THAT - Though there are some revenue implications in the submissions made by the learned Additional Solicitor General with respect to the Financial Year 2011-2012, we are not inclined to interfere with the judgment of the High Court in the fact and circumstances of the present case, we keep the question of law open. The Special Leave Petition is dismissed.

Summary

The Supreme Court dismissed the Special Leave Petition and kept the question of law open. Delay was condoned, and pending applications were disposed of. The judgment of the High Court was not interfered with regarding revenue implications for the Financial Year 2011-2012.