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| The Tax Publishers2020 TaxPub(DT) 2654 (Bom-HC) : (2020) 426 ITR 0228 : (2020) 317 CTR 0009 : (2020) 272 TAXMAN 0255 INCOME TAX ACT, 1961
Section 148
Assessee furnished all related details and information sought for by AO during original assessment. Several hearing took place as regards issue being subject-matter of impugned proceedings and thereafter AO concluded assessment proceedings by passing assessment order under section 143(3), therefore, it could not be said that assessee did not disclose fully and truly all material facts necessary for assessment and consequently reopening beyond four years was hit by proviso to section 147 and section 148 notice was set aside.
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Reassessment - Notice beyond four years - No failure to disclose fully and truly all material facts -
AO received information from investigation wing as to assessee being beneficiary of providers of bogus long-term capital gain on sale of shares and accordingly AO issued notice under section 148 after expiry of four years from the end of relevant assessment year so as to reopen assessment.Held: As evident from materials on record, assessee furnished all related details and information sought for by AO during original assessment. Several hearing took place as regards issue being subject-matter of impugned proceedings and thereafter AO concluded assessment proceedings by passing assessment order under section 143(3). Accordingly, it could not be said that assessee did not disclose fully and truly all material facts necessary for assessment and consequently reopening beyond four years was hit by proviso to section 147 and section 148 notice was set aside.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
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