RAMANASEKHAR STEELS LTD.,COIMBATORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE RANGE -5, CHENNAI

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ITA 2319/CHNY/2017Status: DisposedITAT Chennai31 March 2022AY 2007-0810 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were initiated beyond the four-year period without fulfilling the conditions of the first proviso to Section 147 of the Act. The Tribunal also found that there was no new tangible material before the AO, indicating a change of opinion.

What were the facts?

The assessee filed an appeal against a reassessment order for AY 2007-2008. The AO initiated reassessment proceedings after the expiry of four years from the end of the assessment year.

What were the issues?

Whether reassessment proceedings initiated after four years are valid without fulfilling the conditions of the first proviso to Section 147, and whether it constitutes a change of opinion.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(1)Show list

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Income Tax Appellate Tribunal, “D” BENCH, CHENNAI

Before: SHRI C.M. GARG, JM & SHRI ARUN KHODPIA, AM

For Respondent: Shri G.Jonhnson, Addl. CIT
Hearing: 24/02/2022Pronounced: 31/03/2022

आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : अपीलाथ� / The Appellant- 1.

��थ� / The Respondent- 2.

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