MANJU KUMAR Vs. INCOME TAX OFFICER
INCOME TAX APPELLATE TRIBUNAL
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J. Kathuria, Accountant Member -
(1.) THESE six appeals by the assessee pertain to assessment years 1985-86 to 1991-92, except assessment year 1987-88. Since these appeals raise common issues, these are disposed of by a consolidated order for the sake of convenience.
(2.) Brief facts of the case are these: For assessment year 1985-86, original assessment was made on 5-5-1987 vide order under Section 143(1) of the Act. Later on, while scrutinising the case of the assessee for subsequent years, the Assessing Officer found that the assessee had claimed interest on interest on the loans borrowed for the construction of the property which was yielding income to the assessee. He accordingly recorded the reasons, a copy of which has been supplied by the assessee at page 4 of her compilation. The proceedings were reopened by issue of notice under Section 148 sometime in February 1992. In the said reasons the Assessing Officer mentioned that for assessment year 1987-88, the income from property falling to the assessee's share was Rs. 1,34,124 and since the returned income was almost the same, in the earlier years and the deduction on account of interest and other allowances was also almost the same, the income from property for assessment year 1985-86 had escaped assessment to the extent of Rs. 83,301 representing the difference between Rs. 1,35,000 and Rs. 51,690 (as orginally assessed).
For assessment year 1986-87 also the original assessment had been made under Section 143(1) of the Act on 30-6-1987 and for similar reasons proceedings under Section 148 were initiated.
(3.) FOR assessment years 1988-89, 1989-90 and 1990-91 original assessments had been made under Section 143(3) of the Act. Later on, the Assessing Officer learnt that the assessee had shown only 20% share in the rental income of property known as SCO Nos. 57, 58 and 59 in Sector 17-A, Chandigarh whereas, in fact, the assessee's share was 25%, He accordingly reopened the proceedings for these three assessment years by issue of notice under Section 148.;
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