Assessee-company is\u00a0 carrying on mining business . \u00a0During year under consideration an e-auction of Iron Ore (mining) had been conducted by monitoring committee appointed by Supreme Court of India by assessee and total e-auctioned amount for financial year 2011-12 was determined . Assessee had filed its return of income for assessment year 2012-13 . \u00a0Subsequently, notice under section 148 was issued after expiry of four years from filing of return for reasons that as company maintained its account as per mercantile system, e-auctioned amount in financial year 2011-12 (assessment year 2012-13) had to be accounted in same year . Allowing the petition the Court held that\u00a0 from records it was found that assessee had made complete disclosures and informed revenue that during assessment year 2012-13, certain tons of ore was e-auctioned by Monitoring Committee and it received no portion of sale proceeds during said year and sale proceeds were ultimately received during assessment year 2013-14, which was duly accounted for during said year .\u00a0\u00a0 From records, it was apparent that assessee did not fail to disclose fully and truly all material facts necessary for its assessment for relevant assessment year 2012-13 and therefore, the notice and order disposing the objection is quashed and set aside .\u00a0 \u00a0to reopen assessment was to be quashed and set aside . (AY. 2012 -13)<\/p>\n","protected":false},"excerpt":{"rendered":"
S.147: Reassessment \u2013 After the expiry of four years – No failure to disclose material facts \u2013 Year of taxability \u2013 Mercantile system of accounting \u2013Reassessment notice and order disposing the objection is set aside . [ S.5, 145, 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-49396","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-cQI","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/49396","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=49396"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/49396\/revisions"}],"predecessor-version":[{"id":49397,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/49396\/revisions\/49397"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=49396"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=49396"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=49396"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}