Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
HC upheld the validity of reassessment proceedings initiated u/s 147 against the assessee. It held that the AO had correctly formed a reason to believe that income had escaped assessment due to the assessee's failure to fully and truly disclose all material facts necessary for assessment, specifically the agreement with the Central Government required for claiming deduction u/s 42. Mere disclosure of the deduction claim in the audit report and return of income was held insufficient in the absence of the underlying agreement. Accepting the concurrent factual findings of the AO, CIT(A), and Tribunal, HC found no perversity warranting interference. The reassessment was held to be within limitation and legally sustainable. The appeal was dismissed and decided against the assessee.
HC upheld the validity of reassessment proceedings initiated u/s 147 against the assessee. It held that the AO had correctly formed a reason to believe that income had escaped assessment due to the assessee's failure to fully and truly disclose all material facts necessary for assessment, specifically the agreement with the Central Government required for claiming deduction u/s 42. Mere disclosure of the deduction claim in the audit report and return of income was held insufficient in the absence of the underlying agreement. Accepting the concurrent factual findings of the AO, CIT(A), and Tribunal, HC found no perversity warranting interference. The reassessment was held to be within limitation and legally sustainable. The appeal was dismissed and decided against the assessee.
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