DCIT CC 4(4), MUMBAI, MUMBAI vs. ASPEN INTERNATIONAL PRIVATE LIMITED, MUMBAI
In the result, all the appeals of the assessee are allowed and all the appeals of the Revenue are dismissed
ITA 3593/MUM/2023[2015-16]Status: DisposedITAT Mumbai05 Apr 2024AY 2015-16
Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI S RIFAUR RAHMAN (Accountant Member)
Section 133ASection 143(3)Section 147Section 148Section 149Section 151Section 69C
also incorrectly stated that provisions of section 147(2)(b) are applicable, whereas in the facts of the case provisions of section 147(2)(c) are applicable where the onus on AO is higher to prove escapement of income.
The AO, therefore, recorded wrong, incorrect and non-existing reasons