ABCI INFRASTRUCTURES PRIVATE LIMITED,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI
In the result, the appeal of the assessee is allowed, whereas the appeal of the Revenue is dismissed
ITA 40/GTY/2022[2013-14]Status: HeardITAT Guwahati03 Apr 2023AY 2013-14
Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad
For Appellant: (1) That on the facts and in the circumstances of the case
Section 143(3)Section 147Section 148Section 153Section 153C
reassessment order was passed on 18.12.2017 under section 143(3) read with section 147. Therefore, proviso to this section would puts an embargo upon the powers of the ld. Assessing Officer to issue a notice upon the assessee unless he demonstrated that on account of failure on the part of the assessee to disclose fully and truly all material facts