Shankar Logistics P. Ltd. v. Dy. CIT (2024) 115 ITR 10 (SN)(Kol)(Trib)

S. 147: Reassessment-After the expiry of four years-Information from investigation wing-Accommodation entry-Reassessment is invalid. [S. 133(6), 148]

Held that the Assessing Officer cannot reopen the assessment merely on the basis of information from investigation wing  without correlating it with the facts of the case. There was no allegation that the assessee’s escaped assessment is  due to non-disclosure of the facts necessary for the assessment and since the assessment had been reopened four years after the end of the relevant assessment year. Reassessment  is quashed. (AY. 2012-13)

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