ULO SYSTEMS LLC.,GURGAON vs. ADIT, DEHRADUN
In the result, both the appeals of the assessee are allowed
ITA 5278/DEL/2011[2005-06]Status: DisposedITAT Delhi19 Jun 2018AY 2005-06
Bench: Shri Bhavnesh Saini & Shri L.P. Sahu
For Appellant: Sh. Nageswar Rao (Adv.) &For Respondent: Sh. Satpal Gulati (CIT DR)
Section 115ASection 143(1)Section 143(3)Section 147Section 148Section 44BSection 44D
…n Industries 363 ITR 625 held that reasons u/s 148 of the Act must be based on new and tangible materials. Notice passed on documents already on record is not valid. 11. Hon’ble Bombay High Court in the case of Sadhna Nitro Chem Ltd. Vs. ACIT & others ACIT 368 ITR 505 (Bom) held as under:- “ Where assessments are sought to be opened beyond a period of four years from the end of the relevant assessment year before a notice to reopen can be issued, the condition precedent must be satisfied, i.e., failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. Held, a…