The Assessing officer issued five notices without stating the reasons\u00a0 however\u00a0 six separate intimations, \u00a0the Assessing Officer informed to assessee reasons for reopening assessment years wherein it was stated that on perusal of ITR filed by assessee during survey u\/s 133A, it was noticed that assessee had claimed expenses equivalent to 59.23%, 51.10%, 38.79%, 26.71%, 28.88% & 35.24% in respective assessment years \u00a0in question.\u00a0 Assessee had failed to furnish details despite sufficient time was granted\u00a0 The asseessee filed the writ petition cahllnging the notice under section \u00a0147\/ 148. Dismissing the petition the Court held that if\u00a0 assessing Officer \u00a0had reasons to believe that income had escaped assessment, he could issue a notice for passing order u\/s 147. Sufficiency of those reasons could not be gone into by High Court if \u00a0relevant germane reasons exist and have been communicated to assessee that was enough for reassessment proceedings to hold field During scrutiny, assessee was further asked to furnish details of invoices for expenses incurred however, assessee failed to furnish same. Therefore, it would be improper to hold that Assessing Officer \u00a0had erred in invoking reassessment jurisdiction vested with him under Section 147\/148. Further, assessee had himself replied and participated in impugned proceedings. Reasons were also communicated to assessee to which assessee had also replied. Thus, it was not open for assessee to question same to scuttle proceedings initiated under Act. \u00a0(AY.2012-13 to 2017-2018 )<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 147 : Reassessment \u2013 Reasons communicated -Participated in the proceedings – If relevant germane reasons exist and have been communicated to the assessee that is enough for reassessment proceedings to hold the field- Writ is not maintainable [ S.148 , Art , 226 ] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-18837","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-4TP","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/18837","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=18837"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/18837\/revisions"}],"predecessor-version":[{"id":18838,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/18837\/revisions\/18838"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=18837"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=18837"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=18837"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}