9911796707
TMI Blog2019 (12) TMI 1687X X X X Extracts X X X X X X X X Extracts X X X X ..... ns - assessment reopened beyond a period of four years - HELD THAT:- As pointed out that in the entire reasons recorded, there is not even a whisper regarding any failure on the part of the petitioner to disclose fully and truly all material facts and therefore, the assumption of jurisdiction by the AO u/s 147 of the Act, without there being any failure on the part of the petitioner to disclose fu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r company is a beneficiary of entries of ₹ 50,00,000/- from a transaction with Shri Pravin Agarwal and Shri Kamalkant Das (entry operators) and their sister concerns. It was further pointed out that according to the Assessing Officer, though the petitioner had filed a return of income for the year under consideration, there was no assessment and that the provisions of clause (b) of Explanati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s reason to believe. It was submitted that thus, the Assessing Officer has proceeded on a factually incorrect basis. 3. It was further pointed out that the Assessing Officer has recorded that though information was called for under section 133(6) of the Act, the petitioner had not filed any supporting evidence. It was pointed out that in fact, the petitioner had responded to the said notice under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mption of jurisdiction by the Assessing Officer under section 147 of the Act, without there being any failure on the part of the petitioner to disclose fully and truly all material facts, is without authority of law. 5. Having regard to the submissions advanced by the learned advocate for the petitioner, issue Notice, returnable on 20.01.2020. By way of ad-interim relief, further proceedings pursu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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