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TMI Blog2020 (2) TMI 1338X X X X Extracts X X X X X X X X Extracts X X X X ..... DER S. Jayaraman, The assessee filed this appeal against the order of the Commissioner of Income Tax (Appeals)-7, Chennai in ITA No. 99(t)/CIT(A)-7/2017-18 dated 25.01.2019 for assessment year 2009-10. 2. Shri. B. Suresh Kumar, the assessee, director of M/s. S&S Enterprises is engaging in providing end to end liaison service to various multinational companies and corporate clients engag ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rom the end of the assessment year 2009-10, the AO issued a notice u/s. 148 dated 25.01.2016. In such case, in accordance with first proviso to section 147, the officer should have recorded the reason of failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment in that assessment year. In this case, there is no fresh material and there is no fa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ar, the AO can proceed to reassess the income only when he records the reason of failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment in that assessment year. In this case, the material on which the Assessing Officer reopened were filed by the assessee was very well considered by the AO. Therefore, the notice issued u/s. 147 does not satis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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