Reopening based on incorrect fact understanding is unsustainable: ITAT Mumbai

Indian Hotels Company Limited Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that the very basis of which the Assessing Officer formed the belief that the income liable to tax is escaped assessment was based upon incorrect understanding of the facts and is, therefore, not sustainable in the eyes of law.

Facts- The present appeal has been preferred by the assessee mainly contesting that the reason recorded by the Assessing Officer were not in compliance with the First Proviso to Section 147 of the Act. In the present case assessment was framed on the Assessee under S

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