sec. 147 & 148 of the IT Act.


20 July 2011 Case: A survey action was undertaken at the office of a Chartered Accountant and all the client's files were seized. Based on these cases of all such clients were reopened. Is this a valid reason for reopening? I need case law(s) on this issue..

Thanx...

20 July 2011 on primary looks there must have been some interconnection with all files, or common loans,

if any such clue is found by department then they are right to open these files.

21 July 2011 interconnection is not relevant.....147/148 can be invoked only when there is any additional material/info on records.....the files of these clients, whose cases were reopened, contained all IT data, ROI and computation...already filled with the dept....

anyways, my question is, 'can my case be reopened, i.e.147/148 can be invoked, based on the data found during the course of survey at the place of 3rd party......? if yes, which sec/ case law gives such permission...??




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