Dismissing the petition the Court held that although materials were disclosed during the course of assessment, the prima facie fact reveals that the deduction was wrongly claimed twice in the primary material and contains incorrect particulars. There was no proper declaration of income in the return of income. The AO cannot be faulted while reopening the Assessment and overrule the objection of the assessee. Further, Explanation to s. 147 makes it clear mere filing of information is not sufficient. (AY. 2014-15)
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