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TMI Blog2019 (7) TMI 806X X X X Extracts X X X X X X X X Extracts X X X X ..... under Section 143(3) of the Act had been made beyond the period of four years by issuing notice under Section 148 of the Act without any allegation that the income chargeable to tax had escaped assessment for such assessment year by reason of the failure on the part of the assessee to disclose fully and truly all the material facts necessary for his assessment for that assessment year. The Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on facts in upholding the decision of CIT(A) quashing the proceedings initiated under Section 147 of the Act?" 3 The findings recorded by the Tribunal as regards the proposed question are as follows: "10. The second basis for treating the reassessment proceedings and order as bad in law is noncompliance of first proviso to S. 147 of the Act. Undisputedly and admittedly, the initiation of rea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... initiation of reassessment proceedings of assessment order passed u/s. 143(3) of the Act has been made beyond four years by issuing notice u/s. 148 of the Act on 22.06.2010 without any allegation that the income chargeable to tax has escaped assessment for such assessment year by reason of the failure on the part of the assessee to disclose fully and truly all material facts necessary for his ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessment for that assessment year. The Tribunal, while concurring findings recorded by the CIT(A) clearly held that the initiation of reassessment proceedings under Section 147 of the Act was bad in law. 5 In view of concurrent findings recorded by the two Revenue authorities, we are not inclined to disturb the order passed by the Tribunal. No error much less an error of law could be said to hav ..... X X X X Extracts X X X X X X X X Extracts X X X X
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