Dismissing the appeal of the Revenue the Court held that the reopening was based on a statement made by a director of the assessee’s share broker company but no opportunity was given to the assessee to cross-examine him. The order of the Tribunal setting aside the order of the Assessing Officer is affirmed. (AY.2009-10)
PCIT v. Prabhu Dayal Aggarwal (2023)456 ITR 84 /154 taxmann.com 506 (Delhi)(HC)
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-No opportunity of cross-examination is given-Reassessment is not valid.[S. 148, 260A]