Assessee received certain sum towards share capital and unsecured loans. After making enquiries the assessment was completed u\/s 143((3) of the Act. The assessment was re opened on the\u00a0 ground that\u00a0 the assessee was a beneficiary of accommodation entries. However, reasons for reopening assessment furnished by Assessing Officer did not record that there was a failure on part of assessee to disclose, truly and fully, all material facts necessary for carrying out assessment. Tribunal held that\u00a0 the\u00a0 Assessing Officer failed to apply its mind independently and that it reopened concluded assessment based on directions of Director of Investigation. Tribunal returned a finding of fact that none of 99 share capital applicants were found in list of accommodation entry providers. Assessee had already been put to scrutiny with regard to infusion of share capital and had furnished relevant information sought by Assessing Officer when initial assessment order was framed under section 143(3) of the Act.\u00a0\u00a0 Tribunal quashed the reassessment proceeding.\u00a0 On appeal dismissing the appeal of the Revenue the court held that\u00a0 reassessment was due to change of opinion. Order of tribunal quashing the revision order is affirmed. (AY. 2007-08)<\/p>\n","protected":false},"excerpt":{"rendered":"
S.147: Reassessment-After the expiry of four years-Share capital-No failure to disclose material facts-Reassessment order quashing the reassessment is affirmed. [S. 68, 143(3), 148, 260A]<\/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-38225","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-9Wx","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/38225","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=38225"}],"version-history":[{"count":2,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/38225\/revisions"}],"predecessor-version":[{"id":51605,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/38225\/revisions\/51605"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=38225"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=38225"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=38225"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}