LOVELY PROMOTERS PRIVATE LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE, AJMER, AJMER
In the result, the appeal filed by the assessee is allowed
ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14
Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w
For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a
Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C
reassessment of escaped income but to tap undisclosed income in a search related case, S. 148 has no jurisdiction. The Appellant is a person related to search. The issue of Notice u/s. 148 is not tenable as it is a search related case (as per AO’s himself
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Lovely promoters Pvt. Ltd. vs. ACIT allegation which was confirmed