Initiation of Re-assessment u/s 147 Requires new Tangible Material: ITAT

Telecon Consultancy Services LLP Vs ACIT (ITAT Ahmedabad) Introduction: In a recent decision by ITAT Ahmedabad, the guidelines surrounding the initiation of re-assessment proceedings under section 147 of the Income Tax Act came to light. The case in point was “Telecon Consultancy Services LLP Vs ACIT”, where the crux of the matter was whether the Assessing Officer (AO) could initiate proceedings without any tangible evidence indicating the escape of income. Analysis: The dispute initiated when the AO, based on previous records, believed there was an evasion of tax and initiated the...