Income Escapement Alone Insufficient to Reopen Assessment under Section 147 Without Assessee’s Disclosure Failure: Delhi HC

Discovery Communications India Vs ACIT (Delhi High Court) Delhi HC order whether reassessment u/s 147 permissible for AO after closure of proceedings u/s 143 resulting in under assessment of income The Delhi High Court has made it clear that once scrutiny assessment is held under Section 143 of the Income Tax Act but due to a mistake of the Assessing Officer there is under assessment of income, reopening assessment under Section 147 of the Income Tax Act, 1961 is not permissible. “…AO specifically records in the reasons that it was a ‘mistake’ which resulted in under assess...