Case Law Details
Pillu Ram Sahal v. ITO (ITAT Jaipur)
The issue under consideration is whether the re-opening of assessement u/s 147 is justified in law?
ITAT states that, in the instant case, the AO has found out the facts of deposit of cash of Rs. 14.00 lacs in the bank account of the assessee and no return of income has been filed by the assessee for the year under consideration. Thus this very fact of deposit of cash of Rs. 14.00 lacs and not filing of the return of income by the assessee itself constitute a tangible material to form the belief that income assessable to tax has escaped assessment. ITAT further note that JCIT after considering the reasons also recommended the reasons recorded by the AO for issuing notice u/s 148 of the Act. Based on these facts, the ld. Pr.CIT finally granted the approval. Therefore, it was not a case where the prudent person could have taken another view or opinion. Accordingly, ITAT do not find any error or illegality in the impugned order of the ld. CIT(A) upholding the validity of reopening of the assessment.
FULL TEXT OF THE ITAT JUDGEMENT
This appeal by the assessee is directed against the order of ld. CIT(A), Ajmer dated 28-01-2019 for the Assessment Year 2010-11. The assessee has raised the following grounds.
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