2017 (1) TMI 847

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.... P. C. 1. This Appeal under Section 260A of the Income Tax Act, 1961 (the Act) challenges the order dated 12th February, 2014 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order is in respect of Assessment Year 1997-98. 2. The Revenue urges the following question of law for our consideration :Whether on the facts and circumstances of the case, the Tribunal was co....

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....sued a notice under Section 148 of the Act seeking to reopen the assessment for the subject assessment year . The reasons in support of the reopening notice as reproduced in the impugned order read as under : "1. While computing business loss, the same was wrongly taken at Rs. 15,374.16 lakhs as against the correct amount of Rs. 12,587.79 lakhs as per the revised return. 2. Provi....

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....om the end of the relevant assessment year, without anything being on record to indicate any failure on the part of the respondent assessee to fully and truly disclose all material facts. This particularly in the context of the regular assessment having been done under Section 143(3) of the Act. 6. Being aggrieved, the Revenue filed an appeal to the Tribunal. The impugned order finds that the r....