HERVE POMERLEAU INTERNATIONAL CCCL JOINT VENTURE,CHENNAI vs. ACIT, NON CORP CIR-1, CHENNAI

In the result, the ITA No

Bench: Shri George Mathan & Shri Inturi Rama Rao

147 is not valid. 2.1 The CIT (A) is not justified in concluding that the re-opening of assessment by issue of notice u/s 148 is valid 2.2 The CIT (Appeals) erred in considering the argument of Addl.CIT that merely because the Assessee makes submission to Assessing Officer does not automatically imply that an opinion is formed on the said