DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. SECO TOOLS INDIA PVT. LTD.,, PUNE

In the result, the Cross Objections of assessee are allowed and appeals of Revenue are dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.812 & 813/Pun/2017 यििाारण वषा / Assessment Years : 2002-03 & 2003-04

36(1)(iii) of the Income-tax Act, 1961, on the facts and circumstances of the case, and in law, the Ld. CIT(A) has erred in confirming the action of the Learned Assessing Officer [„Ld.AO‟] in reopening the assessment proceedings without any „reason to believe‟ as required by the provisions of section 147. It is prayed that the reassessment