Reopening of assessment u/s 147 - Whether AO has assumed the ...
Assessment Reopened u/s 147 Due to Incorrect Facts; Taxpayer's Filed Return Overlooked by Assessing Officer.
August 20, 2022
Case Laws Income Tax AT
Reopening of assessment u/s 147 - Whether AO has assumed the jurisdiction on wrong facts? - The date of filing of the return is much before than the date of recording of reasons which is 27.03.2019. AO has noted that PAN was searched in the system and DCR of respective year has also been consulted and he had not found the copy of return filed by assessee. In view of the fact of having filed the return of income by the assessee the finding of the Assessing Officer that no return has been furnished by the assessee is wrong and therefore AO has reopened the case by recording a wrong fact. - AT
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