2020 (10) TMI 845

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....the Assessment Year 2004-05. The Tax Case Appeal was admitted on 22.11.2019 on the following Substantial Questions of Law: "(i)Whether under the facts and circumstances of the case, the Income Tax Appellate Tribunal was right in quashing the reassessment proceedings initiated by the revenue, holding that there is no failure on the part of the assessee to disclose fully and truly material facts necessary for the assessment during the original assessment? (ii)Whether based on the material available before it, the Income Tax Appellate Tribunal could have arrived at a conclusion that there is no failure on the part of the assessee to disclose fully and truly material facts necessary for the assessment during the original asses....

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.... offered by the assessee did not find favour with the Assessing Officer, who rejected the same and completed the assessment under Section 143(3) read with Section 147 by order dated 28.12.2011. The assessee being aggrieved, filed an appeal before the Commissioner of Income Tax (Appeals), Chennai, ('CIT(A)' for brevity). Among other things, the assessee questioned the reopening of the assessment under Section 147 of the Act. The assessee contended that the scrutiny assessment was already completed after hearing the assessee, after perusing the return, statements of account furnished by it and after examining the books of accounts maintained for the business carried on by the assessee and there was no failure on the part of the assess....