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TMI Blog2019 (8) TMI 738X X X X Extracts X X X X X X X X Extracts X X X X ..... ICE J.B.PARDIWALA) 1 This Tax Appeal under Section 260A of the Income Tax Act, 1961 [for short, "the Act, 1961"] is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Surat Bench, Surat dated 28th September 2018 in the I.T.A. No.1006/AHD/2015/SRT for the assessment year 2006-07. 2 The Revenue has proposed the following question of law ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erusal of the reasons recorded for reopening shows that the AO has not mentioned that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. Even the assessment order also makes no mention of such failure on the part of the assessment. It is also noticed that assessee has filed objection vide letter dated 21.01.2013, but these obj ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by reason of failure on the part of assessee to disclose fully and truly all material facts necessary for assessment for the relevant assessment year, the very initiation of proceedings u/s.l47 by issuance of notice u/s.148 after expiry of four years from the end of relevant assessment year is bad and cannot be sustained. 7 In the light of above facts, we are of the considered opinion that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the fact that the Tribunal has relied upon a decision of this Court in the case of Sadbhav Engineering Ltd vs. DCIT [(2011) 33 ITR 483].
5 In the overall view of the matter, we are convinced that no error, not to speak of any error of law could be said to have been committed in passing the impugned order.
6 In the result, this appeal fails and is hereby dismissed. X X X X Extracts X X X X X X X X Extracts X X X X
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