ACIT vs. INTERNATIONAL SCHOOL OF SOCIAL WELFARE HUMAN RESOURCES,

In the result, the appeal filed by the Revenue is allowed while the Cross Objection filed by the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Rakesh Mishra

6. First we would take up the Revenue’s appeal. The Ground of Appeal in I.T.A. No. 119/PAT/2011 is that the Ld. CIT(A) grossly erred both in fact & in law in quashing the initiation of proceedings u/s 147 of the Income-tax Act, 1961 by applying the second proviso of section 147 of the Income