In the result, the appeal of the assessee is allowed
Bench: Sh. N. K. Saini, Hon’Ble & Sh. Ravish Soodita No.181/Asr./2017 : Asstt. Year : 2008-09 M/S Holy Faith International Vs Deputy Commissioner Of Income Tax, Pvt. Ltd., Mbd House, Central Circle-Ii, Railway Road, Jalandhar Jalandhar (Appellant) (Respondent) Pan No. Aaach6111J Assessee By : Sh. Sudhir Sehgal, Adv. Revenue By : Sh. Bhawani Shankar, Dr Date Of Hearing : 07.01.2019 Date Of Pronouncement : 15.01.2019 Order Per N. K. Saini: This Is An Appeal By The Assessee Against The Order Dated 20.03.2017 Of Ld. Cit(A)-I, Jalandhar. 2. Following Grounds Have Been Raised In This Appeal: “1. That The Worthy Commissioner Of Income Tax (A)-1, Jalandhar Has Erred In Dismissing The Appeal Filed By The Assessee. 2. That The Ld. Cit(A) Has Erred In Confirming The Contention Of The Assessing Officer In Reopening The Case U/S 148 Of The Income Tax Act And, Thus, Framing Of Assessment U/S 147 R.W.S.143(3)/153C At An Income Of Rs. 4,95,13,441/- Against The Returned Income Of Rs. 4,63,33,441/-. 3. That The Ld. Cit(A) Has Erred In Not Considering That There Was No Reason To Believe That The Income Of The
section 147 is not satisfied with regard to reopening the case beyond 4 years. Now, the point wise explanation of the above points are provided as under: 1.4 It is submitted that the case of the assessee has already been assessed u/s 153C/143(3) of the Act and the then Ld. AO has applied his mind while framing his assessment