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Friday, May 22, 2020

[ACCA_Profs] Tax Experts Explain Law On 'Full And True Disclosure Of Material Facts' For Reopening U/s 147 Of Income-Tax Act

 

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Full And True Disclosure – A Fetter On The Power Of The AO To Reopen

Advocates Mahendra Gargieya and Hemang Gargieya have explained the law relating to "full and true disclosure of material facts" in the context of reopening under sections 147 and 148 of the Income-tax Act, 1961. The ld. authors have explained the fine distinction between the obligation of the assessee to disclose the "material facts" and the requirement to disclose the "inferences" to be drawn from those facts. They have opined, by relying on judgements of the Apex Court, that while the assessee is required to disclose the former, he is not obliged to disclose the latter

See Also: Digest of case laws (updated regularly) containing latest judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals


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Editor,

 

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