2022 (3) TMI 65

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... ORDER PER RAJESH KUMAR , ACCOUNTANT MEMBER The present appeal has been preferred by the assessee against the order passed u/s. 143(3)/147 of the Income Tax Act (hereinafter referred to as the 'Act') by the Commissioner of Income Tax(Appeals)-1, Kolkata (hereinafter referred as the 'CIT') relevant to A.Y. 2007-08. 2. The assessee has challenged the order of the CIT(A) upholdin....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ment has been framed u/s. 143(3) of the Act, no action shall be done only under this Act after expiry of four year from the end of relevant assessment year unless the income chargeable to tax has escaped assessment by reason of failure on the part of the assessee to disclose fully and truly all material facts for assessment of income in that assessment year. The Ld. A.R. submitted that the assessm....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....amount of TDS in the Government account well within time, however due to typographical mistake the assessment year was wrongly mentioned in the challan resulting into non-mentioning of the same in the TIN system. The Ld. A.R. submitted the said mistake was rectified and necessary evidences are filed in the paper book. The Ld. A.R. also referred to the rectified/corrected challans filed in the pape....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

...., the same may be referred back to the file of Assessing Officer for necessary verification and the Assessing Officer may allow the claim of the assessee after verification of the corrected challans. 4. After hearing the rival submissions and pursued the relevant records. We find in this case, the reopening was made after period of four years on the end of relevant assessment year. The assessment....