Case Law Details
Case Name : Moser Baer India Limited Vs Deputy Commissioner of Income Tax & ORS (Delhi High Court)
Related Assessment Year :
Courts :
All High Courts Delhi High Court
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When there was intensive examination in the first instance in respect of the issue, which was the basis for re-opening of assessment, it was necessary for the AO to indicate, what other material, or objective facts, constituted reasons to believe that the assessee had failed to disclose a material fact, necessitating reassessment proceedings.
That is precisely the “tangible material” which have to exist on the record for the “reasons” (to believe” bearing a “live link with the formation of the belief” as spelt out in Kelvinator. When the assessment is completed, as in the present...
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Revenue DEptt should open its eyes before3 issuing any such notice for harassing hapless Assessees !