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TMI Blog2019 (2) TMI 539X X X X Extracts X X X X X X X X Extracts X X X X ..... A was examined by the Assessing Officer in the original assessment proceedings. Despite this, if the AO was in possession of information then not available to him, sufficient to enable him to form a belief that income chargeable to tax had escaped assessment, reopening of assessment that too beyond the period of four years could still be resorted to. In the present case the entire information ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Income Tax Appellate Tribunal ( the Tribunal for short) dated 23.9.2015 raising following question of law for our consideration:- Whether on the facts and in the circumstances of the case and in law, the Tribunal has erred in quashing the proceedings under Section 147 of the I.T. Act by merely saying that it is change of opinion of the Assessing Officer without considering the fact th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ad referred to the investigation carried out by the Customs Department on the components imported by the assessee through M/s. Eastern Peripherals for SCADA alleging that no duty was paid. He noticed that the said M/s. Eastern Peripherals had thereupon filed declaration under Kar Vivad Samadhan Scheme of 1998 ( KVSS for short) and assessee had undertaken to pay residual duty. On the basis of such ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s, if the Assessing Officer was in possession of information then not available to him, sufficient to enable him to form a belief that income chargeable to tax had escaped assessment, reopening of assessment that too beyond the period of four years could still be resorted to. In the present case, however, the entire information or material which the Assessing Officer now seeks to place reliance up ..... X X X X Extracts X X X X X X X X Extracts X X X X
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