Assessing Officer reopened assessment in case of assessee beyond four years\u00a0 on the ground that\u00a0 the\u00a0 assessee’s bank account was credited by by three transactions on various dates from account of \u00a0Sarathak Enterprises \u00a0and same amount was debited on same dates to account of Munjal B.Shah \u00a0and he opined that said amount remained unexplained in hands of assessee. However, communication whereby reasons recorded were supplied, no satisfaction was recorded by Assessing Officer that income chargeable to tax had escaped assessment.\u00a0 From facts it was evident that amount was received by assessee as partners’ capital and had a valid source.\u00a0 Assessee had utilised amount for repayment of loan obtained from Munjal B.Shah.\u00a0 \u00a0High Court held that question of escapement of income chargeable to tax did not arise and thus, Assessing Officer having misdirected himself in invoking powers to reopen assessment, reassessment proceeding initiated beyond four years was\u00a0 set aside. SLP of revenue is dismissed\u00a0 (AY. 2013-14)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 147 : Reassessment-After the expiry of four years-Cash credits-Partners capital account-No satisfaction was recorded-Reassessment notice and order disposing the objection quashed by the High Court is affirmed-SLP of revenue is dismissed. [S. 68, 148, Art. 136] <\/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-46653","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-c8t","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/46653","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=46653"}],"version-history":[{"count":4,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/46653\/revisions"}],"predecessor-version":[{"id":52977,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/46653\/revisions\/52977"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=46653"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=46653"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=46653"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}