Shri Anil Singhal, Muzaffarnagar vs. ITO, Muzaffarnagar
In the result, the appeal of the assessee in ITA No
ITA 2044/DEL/2017[2008-09]Status: DisposedITAT Delhi04 Oct 2017AY 2008-09
Bench: Shri B.P. Jainassessment Year 2008-09 Anil Singhal C/O. Dinesh Vs. Ito, Mohan, Advocate, 2- Anand Ward-1(1) Vihar, Lane No. 1, Circular Muzaffarnagar Road, Muzaffarnagar Pan-Bksps7631E (Appellant) (Respondent) Appellant By : Sh. Ankit Gupta, Adv Respondent By : Sh. T. Vasanthan, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 04/10/2017 घोषणा क" तार"ख /Date Of Pronouncement: 04/10/2017 Order Per B.P. Jain, A.M. This Appeal Of The Assessee Arises From The Order Of Learned Cit(A), Muzaffarnagar, Vide Assessment Order Dated 24.01.2017 For The Assessment Year 2008-09. The Assessee Has Raised As Many Eleven Grounds Of Appeal & First Four Grounds Being Legal Which Have Been Pressed By The Assessee Are Reproduced Hereinbelow:- That The Notice Issued U/S 148 & Reassessment Order Passed U/S 147 R.W.S. 1) 144 Are Illegal, Bad In Law & Without Jurisdiction. That, In View Of The Facts & Circumstances, No Satisfaction Is Recorded By 2) The Assessing Officer As Required U/S 147/148 Of The Act Prior Issuing The Notice Under Section 147 Of The Income Tax Act, 1961. That, No Satisfaction Has Been Recorded By The Assessing Officer After 3) 2
For Appellant: Sh. Ankit Gupta, AdvFor Respondent: Sh. T. Vasanthan, Sr. DR
Section 144Section 147Section 148
…eedles Pvt. Ltd.) 9. The Court at the outset proposes to recapitulate the jurisdictional requirement for reopening of the assessment under Section 147/148 of the Act by referring to two decisions of the Supreme Court. In Chhugamal Rajpal vs. SP Chaliha (1971) 79 ITR 603, the Supreme Court was dealing with a case where the AO had received certain communications from the Commissioner of Income Tax showing that the alleged creditors of the Assessee were “name lenders and the transactions are bogus. ” The AO came to the conclusion that there were reasons to believe that income of the Assessee had escaped assessment.…
