Court : Income Tax Appellate Tribunal ITAT Guwahati
Reported in : (1988)24ITD440(Gau.)
..... were before the ito at the time of the original assessment, we hold that the ito had no jurisdiction to re-open the assessment under section 147(a) of the act. the cit(a) was accordingly justified in cancelling the ito's order of re-assessment under section 147(a).7. now coming to the additional ground raised at the time ..... discovered by the income-tax officer will not necessarily amount to disclosure within the meaning of this section.there was a similar explanation to section 34 of the income-tax act, 1922. the scope and intent of explanation to section 34 has been explained, by their lordships of the supreme court in the case of calcutta discount co. ltd. v. ito ..... to the extent of rs. 5,00,000 and, therefore, the ito had the necessary jurisdiction to re-open the assessment within the meaning of section 147(a) of the act. it was pointed out that during the course of reassessment proceedings for the assessment years 1972-73, 1973-74 and 1974-75, the ito on the basis of information gathered .....
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