M/S HOLY FAITH INTERNATIONAL PVT. LTD,JALANDHAR vs. THE DY COMMISSIONER OF INCOME TAX, JALANDHAR
In the result, the appeal of the assessee is allowed
ITA 181/ASR/2017[2008-09]Status: DisposedITAT Amritsar15 Jan 2019AY 2008-09
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
For Appellant: Sh. Sudhir Sehgal, AdvFor Respondent: Sh. Bhawani Shankar, DR
Section 131Section 132Section 147Section 148Section 153C
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
