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TMI Blog2018 (12) TMI 1975X X X X Extracts X X X X X X X X Extracts X X X X ..... and truly all material facts necessary for its assessment, the assumption of jurisdiction on the part of the AO is invalid - Also AO has proceeded on a factually incorrect premise insofar as the value of Alpha Graphics Scrip is concerned as well as on the incorrect premise that no scrutiny assessment was made in the year under consideration. HELD THAT:- Having regard to the submissions advanced ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... which is clearly beyond a period of four years from the end of the relevant assessment year and therefore, the proviso to section 147 of the Act would be attracted. 2. Referring to the reasons recorded, it was pointed out that the Assessing Officer, in paragraph 8 thereof, has recorded that in this case, the return of income was filed for the year under consideration, but there was no scrutiny ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s submitted that after analysing all the material produced by the petitioner, the Assessing Officer had framed the assessment under section 143(3) of the Act by an order dated 13.03.2015 and had allowed the said deduction. It was submitted that when the Assessing Officer had gone into the issue threadbare at the time of scrutiny assessment, it is evident that he now seeks to reopen the assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... long term capital gain has shown the sale price at Rs.71,72,300/- in respect of Alpha Graphics. It was submitted that therefore, the Assessing Officer has proceeded on a factually incorrect premise insofar as the value of Alpha Graphics Scrip is concerned as well as on the incorrect premise that no scrutiny assessment was made in the year under consideration. 5. Having regard to the submissions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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