The Tribunal held that the primary facts were not completely, correctly and truly disclosed by the assessee in the return and there was clearly an attempt to evade taxes. There was a tangible material before the Assessing Officer to reopen the concluded assessment. Thus, the reassessment was valid. Applied ACIT v . Rajesh Jhaveri Stock Brokers P.Ltd ( 2007) 291 ITR 500 (SC) ( AY.2001-02)
K. Srikanth v .ACIT (2020) 80 ITR 272 / 195 DTR 17 /206 TTJ 273 ( Chennai ) (Trib)
S. 147 : Reassessment –With in four years-No scrutiny assessment — Non-compete Fee – Claiming a huge exemption of income by making incomplete, untrue and wrong claim — Primary facts not completely, correctly and truly disclosed in return — Reassessment is held to be valid [ S.143(1) 148 ]