The AO has not linked any material in order to make this observation, he mainly relied on the findings of the AO of another Assessee same conclusion was reversed by the CIT(A) noting that in fact all along there was evidence suggesting that the commencement of construction of the housing project was some time in the year 2002. And the assessment of another assessee was set aside. Hence, there is no part of the to remain undisclosed by the assessee. Reassessment is invalid. (Arising out of 5584 of 2012 dt.15/07/2015)(ITA No.678 of 2016, dt.07/11/2018) (AY. 2004 -05)
PCIT v. Vaman Estate (2020) 113 taxmann.com 405 (HC) Editorial: SLP of revenue is dismissed , due to low tax effect , (SLP No.22927/2019 dt.06/09/2019)(2019)416 ITR 135(St.) (SC) (2020) 113 taxmann.com 406/ 269 Taxman 196 (SC)
S.147 : Reassessment-After the expiry of four years- Reopened on the ground that in another assessee where similar claim with the same housing project – No failure on the part of the assessee to disclose truly and fully all relevant facts – reassessment held to be invalid. [80IB(10)]