2024 (3) TMI 831 - SCH - Income Tax

Reopening of assessment u/s 147 - Eligibility of reasons to believe - AO jurisdiction to issue notice - as decided by HC 2021 (11) TMI 538 - BOMBAY HIGH COURT allegation in the reasons recorded for reopening that petitioner has not disclosed all fully and truly material facts necessary for the assessment is incorrect, one of the condition for reopening the assessment before the AO could assume jurisdiction for issuing notice u/s 148 has not been satisfied HELD THAT - We are not inclined to interfere with the impugned judgment and order passed by the High Court. Hence, the Special Leave Petition is dismissed, however, question of law is kept open to be considered in an appropriate case.

Summary

The Supreme Court dismissed the Special Leave Petition and upheld the judgment of the High Court. The question of law remains open for consideration in the future.