SREE GANESH GEARS PRIVATE LIMITED ,MYSURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2) , MYSURU
In the result, the appeal filed by assessee stands allowed for statistical purposes
ITA 824/BANG/2024[2006-07]Status: DisposedITAT Bangalore07 Jun 2024AY 2006-07
Bench: Smt. Beena Pillai & Shri. Laxmi Prasad Sahuassessment Year : 2006-07 M/S. Sree Ganesh Gears The Deputy Pvt. Ltd., Commissioner Of Plot No. 106, Belegola Income Tax, Industrial Area, Circle – 1(2), Mysuru – 570 016. Mysuru. Vs. Pan: Aaecs8142C Appellant Respondent : Shri Ajith .V, Advocate I/B Shri Assessee By B.S. Balachandran, Advocate : Shri Ganesh R Gale, Standing Revenue By Counsel For Department Date Of Hearing : 30-05-2024 Date Of Pronouncement : 07-06-2024 Order Per Beena Pillaipresent Appeal Has Been Filed By The Assessee Against Order Dated 05/03/2024 Passed By Nfac, Delhi For A.Y. 2006-07. “Legal Grounds: 1. The Order Dated 04 March 2024 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre Is Bad & Erroneous & Against The Facts & Circumstances Of The Case; 2. The Learned Cit(A) Erred In Law & On Facts In Dismissing The Appeal Of The Appellant On The Grounds Of Limitation Without Appreciating That The Appeal Was Filed Within The Time Limit Provided By The Hon'Ble High Court
For Respondent: Shri Ajith .V, Advocate i/b Shri
Section 143(2)Section 143(3)Section 147Section 148Section 154Section 43B
reassessment proceedings initiated by the Ld AO based on change of opinion and without having any tangible material which shows escapement of income, thereby violating the provisions of section 147 of the Act;
5. The learned CIT(A) erred in not appreciating that the Appellant had disclosed all material facts necessary for making an assessment and hence, the notice issued