https://www.taxtmi.com/caselaws?id=255628 The High Court upheld the notice issued under Section 148 of the Income Tax Act, 1961 for reopening assessment for Assessment Year 2007-08. The Court found that the petitioner's disclosure of share capital receipts did not constitute a true and full disclosure, as tangible material suggested the receipt was accommodation entries. Despite the absence of specific language indicating a failure to disclose fully, the Court determined that the notice was not issued mechanically and allowed the reassessment to proceed. The petitioner was granted the opportunity to challenge the reopening notice during the proceedings, with observations made being prima facie and not limiting the Assessing Officer's independent consideration. en-us Wed, 24 Dec 2014 00:00:00 +0530 Thu, 22 Jan 2015 07:08:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255628 The High Court upheld the notice issued under Section 148 of the Income Tax Act, 1961 for reopening assessment for Assessment Year 2007-08. The Court found that the petitioner's disclosure of share capital receipts did not constitute a true and full disclosure, as tangible material suggested the receipt was accommodation entries. Despite the absence of specific language indicating a failure to disclose fully, the Court determined that the notice was not issued mechanically and allowed the reassessment to proceed. The petitioner was granted the opportunity to challenge the reopening notice during the proceedings, with observations made being prima facie and not limiting the Assessing Officer's independent consideration. Case-Laws Income Tax Wed, 24 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255628