AGROH INFRASTRUCTURE DEVELOPERS P LTD,MHOW vs. PR CIT CENTRAL CIRCLE BHOPAL, BHOPAL
In the result, appeal of assessee is allowed
ITA 95/IND/2021[2008-09]Status: DisposedITAT Indore11 Apr 2023AY 2008-09
Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Agroh Infrastructure Pr. Cit (Central) Developers Pvt. Ltd. Bhopal Aqua Point, A.B.Road, Vs. Umaria, Mhow, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaeca 2752 L Assessee By Shri Manish Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2023 Date Of Pronouncement 11.04.2023
Section 143(1)Section 143(3)Section 147Section 148Section 263
198 ITR 297]. Therein the assessee raised a contention that once jurisdiction under Section 147 of the Act is invoked, the whole assessment proceeding became reopened, which was negatived by the court opining:
"Section 147, which is subject to Section 148, divides cases of income escaping assessment into two clauses i.e. viz. (a) those due to the non- submission