2002 (8) TMI 49

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....U J. -The assessee constructed a house commencing some time in the year 1971 and completed it in November, 1974. The assessee had disclosed in his books the amounts spent by him on that construction as Rs. 2,12,000. He subsequently disclosed a further sum of Rs. 60,000 as having been invested in such construction under the voluntary disclosure scheme. After the house was completed in the assess....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nder section 148 of the Income-tax Act, proposing to reassess the income for the assessment years 1972-73 and 1973-74 were issued on March 7, 1983, and for the assessment year 1974-75, the said notice was issued on February 26, 1983. Thereafter on March 31, 1987, the order of assessment was made for the assessment years 1972-73, 1973-74 and 1974-75 adding a sum of Rs. 32,500 in each of those asses....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....f that assessment was not permissible. With regard to the assessment years 1973-74 and 1974-75, the reassessment was upheld by the Tribunal, the Tribunal taking the view that the assessee had not disclosed all the primary factors inasmuch as he had not stated that the money was spent on the construction of the house but had merely stated that certain amount had been "invested in the house". That d....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e instance of the assessee, the following question has been referred to us. "Whether, on the facts and in the circumstances of the case, the Tribunal is correct in holding that the reopening of the assessment for the assessment years 1973-74 and 1974-75 under section 147(a) of the Act is correct, valid, and is not time barred?" We are in agreement with what the Tribunal has stated and the vi....