strategy formulated by the Board from time to time; [(ii) any audit objection to the effect that the assessment in the case of the assessee
States Of Rajasthan vs Prakash Chand & Ors on 2 December, 1997
Equivalent citations: AIR
State Of Rajasthan vs Prakash Chand & Ors on 25 November, 1997
Bench: S.P
Audit Wing). The remark of Accountant General cannot be regarded as information enabling the respondent to reopen the assessment in relation to the audit objection ... audit that income has escaped assessment. In the present case, by scrupulously analysing the audit objection in great detail, the AO has demonstrably shown
case in the audit report it was objected that the tax has been under assessed. The concluding part of the audit objection states ... assessment may be kindly re-examined under intimation to Audit". The said audit objection is dated 10.9.98. The impugned noticed of re-opening
husband and there is some other dues as per audit objection of the year 1985-86 and, therefore, no-dues certificate cannot be issued ... petitioner's late husband and also on account of audit objection of the year 1985-86, no-dues certificate cannot be issued. The respondent
could not be sustained as the same was based on an
„audit objection‟ was concerned, it was observed by the CIT(A) that the
reopening ... audit cell was placed on record. It was
submitted by the ld. A.R that the assessee had replied to the audit
objection
pointed out by audit.
Ratio:
Commissioner under section 263 can exercise jurisdiction on the basis of internal auditor's audit objection, provided he applies ... pointed out by audit.
Ratio:
Commissioner under section 263 can exercise jurisdiction on the basis of internal auditor's audit objection, provided he applies
been satisfied.
2. Reopening of the assessment based on an audit objection
Without prejudice to Ground 1 above, on the facts and in the
circumstances ... have held that the reopening of the assessment based on an audit
objection is bad in law.
3. Reopening of the assessment based
argued that the proceedings were initiated on the basis of the audit objection. The counsel submitted that the assessment proceedings for the immediately succeeding assessment ... officer on 26-2-1999. Therefore, it was submitted that an audit objection was received in the office of the assessing officer