Law on reopening u/s 147 pursuant to an audit objection opposed by AO

1. This Appeal under Section 260A of the Income Tax Act, 1961, challenges the order dated 6 August 2014 passed by the Income Tax Appellate Tribunal. The impugned order dated 6 August 2014 is in respect of Assessment Year 2004-05.

2. Mr. Chhotaray, the learned Counsel for the Revenue, urges only the following question of law for our consideration:-

Whether on the facts and in the circumstances of the case and in law, the Tribunal was justified in quashing the reopening of the assessment particularly when the assessment was reopened within a period of four years from the end of the assessment year?

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