ITA No. 1358/Del/2024 & CO No. 41/Del/2024
Parties Involved
Facts Summary
The case involves the reopening of an assessment under sections 147 and 144 of the Income Tax Act, 1961. The assessee, Raj Kumar Kedia HUF, filed a cross-objection challenging the validity of the reopening. The Assessing Officer had previously framed a section 143(3) assessment on 06.01.2014. The prescribed authority under section 151 of the Act had given approval, but it was deemed mechanical in nature. The Revenue sought to justify the reopening beyond the four-year limit, while the assessee argued against it based on prior assessments and approvals.…
Decision in favour of
Assessee
Legal Issues
- 1. Validity of the reopening of assessment beyond four years from the end of the relevant assessment year.
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
2 precedents cited in this judgement.
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