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Recourse u/s. 147 not prohibited if conditions of reopening u/s. 153C not satisfied
Case Law Details
- Case Name
- PCIT Vs Agroha Fincap Ltd. (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2011-12
- Courts
- All High Courts, Delhi High Court
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PCIT Vs Agroha Fincap Ltd. (Delhi High Court)
Delhi High Court held that non-satisfaction of conditions for reopening assessment u/s. 153C of the Income Tax Act doesn’t prohibit AO from taking recourse u/s. 147. Thus, reopening u/s. 147 based on information from investigation wing justified.
Facts- The Assessing Officer had issued the notice u/s. 148 of the Act. The assessment proceedings culminated in an assessment order passed u/s. 147 of the Act, whereby AO made an addition of ₹25,45,000/- comprising of ₹25,00,000/- u/s. 68 of the Act and ₹45,000/- u/s. 69C of the Act.
CIT(A) reje...
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