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1 - 10 of 62 (0.61 seconds)Section 147 in The Income Tax Act, 1961 [Entire Act]
Section 194C in The Income Tax Act, 1961 [Entire Act]
Section 143 in THE FINANCE ACT, 2021 [Entire Act]
Section 35DDA in The Income Tax Act, 1961 [Entire Act]
Section 147 in THE FINANCE ACT, 2021 [Entire Act]
Commnr. Of Income Tax, Delhi vs M/S. Kelvinator Of India Ltd on 18 January, 2010
5. In view of the above, Mr. Pinto submits that the petition be dismissed.
We have considered the submissions. We find that the notice dated March
20, 2012, under section 148 of the Act has been issued within a period of
four years from the end of the relevant assessment year, i.e., 2007-08. In
such circumstances, the proviso to section 147 of the Act is clearly not
applicable. Therefore, it is not necessary for the Revenue to prima facie
establish that there has been a failure on the part of the petitioner to
disclose fully and truly all material facts necessary for assessment, while
issuing a notice reopening a completed assessment. However, even in case
29 ITA. No.4871/Mum/2014
Landmark Education India
of reopening of assessment within a period of four years from the end of
the relevant assessment year the Assessing Officer has to have reason to
believe that income chargeable to tax has escaped assessment on the basis
of tangible material. The words "reason to believe" has been construed by
the Supreme Court in the matter of CIT v. Kelvinator of India Ltd. [2010]
320 ITR 561/187 Taxman 312 ; wherein the court has observed: