Winsome Textile Industries Limited, Chandigarh vs. Asstt. Commissioner of Income Tax, Circle-4(1), Chandigarh
In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed
ITA 528/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh27 Feb 2025AY 2011-12
Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)
For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Ved Parkash Kalia Sr. DR
Section 115JSection 143(1)Section 143(3)Section 147Section 148
…ferred to in the proviso and it is necessary for the Assessing Officer to record that any one or all the circumstances referred to in the proviso existed before the issue of notice under section 147." (p. 677) Similarly, in Arvind Mills Ltd. v. Dy. CIT [2000] 242 ITR 173 (Guj.), it was held as under:— "It is a clear case where the Assessing Officer has no reason to link escapement of income from assessment with non-disclosure of any material fact necessary for his assessment at the time of original assessment but is due to an erroneous decision on the question of law by the Assessing Officer. Thus, the case is sq…