Thursday, December 15, 2011

SECTION 147


  • The Mumbai High Court in CIT vs. K. Mohan & Co. has held that for the purposes of section 147, retrospective amendment does not mean failure to disclose material facts.
  • The Mumbai High Court in The Indian Hume Pipe Co. Ltd. vs. ACIT has held that for purposes of section 147, "Full & true disclosure of material facts" means "specific" disclosure of "each" fact
  • The Delhi High Court in Atma Ram Properties Pvt. Ltd. vs. DCIT has held thatAO must specify what facts are failed to be disclosed. Lapse by AO is no ground for reopening u/s 147 if primary facts are disclosed.

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