This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Reopening u/s 147 based on mere office note of predecessor AO not permissible
Case Law Details
- Case Name
- Kulbhushan Khosla Vs CIT (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Delhi High Court
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
Advertisement
In this case The reasons for reopening the assessment have been set out in an office note which has been extracted in para 28 of the impugned order of the ITAT. This office note was apparently prepared by the AO at the time of finalizing the initial assessment. It reads as under:
“Office Note
The assessment is completed after detailed discussion with the Additional CIT, R-ll, New Delhi who guided me to make a reference to the F.T.D. Branch to ascertain the genuineness of these NRI gifts. Also make reference to the valuation cell to ascertain the correct value of the assets f...
