Section 147, 148, 143(3). If reopening within a period of four years of assessment u/s 143(3) then there is no bar for reopening of assessment If there is certain non-disclosure. But If reopening beyond four years for assessment already in u/s 143(3) then It must be established that the assessee has not disclosed fully and truly all material evidence with an intention to escape from the payment of tax. motive or intention on the part of the assessee for such non-disclosure is also a material ground. It is a case where the reopening beyond four years of assessment u/s 143(3) and the order of approval, which was validly granted, was produced before the Assessing Officer at the time of scrutiny and the Assessing Officer also accepted the approval order and granted exemption. Thus, the reason stated in the impugned proceedings that the assessee committed a mistake cannot be accepted. M/S.Kone Elevators (India) Pvt. … vs ACIT Madras High Court … on 16 June, 2021
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334 total views Madras High Court M/S.Kone Elevators (India) Pvt. … vs ACIT… on 16 June, 2021 W.P.No.43662 of 2016 Conclusion Section 147, 148, 143(3). If reopening within a period of four years of assessment u/s 143(3) then there is no…
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