Reopening under section 147 For Lapse Of AO Invalid – Delhi High Court

Atma Ram Properties Pvt Ltd vs. DCIT (Delhi High Court)- In the present case, as already noticed, the Income Tax Officer, Azamgarh, subsequent to the completion of the original assessment proceedings,  on making an enquiry from the jurisdictional   Income-tax  Officer at  Calcutta, learnt that the Calcutta company from whom the assessee claimed to have borrowed the loan of Rs. 50,000 in cash had not really lent any money but only its name to cover up a bogus transaction and, after recording his satisfaction as required by the provisions of section 147 of the Act, proposed to reopen the as...