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In the result, all the appeals filed by the assessee are partly allowed as per terms indicated hereinabove
Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1121 To 1126/Pun/2024 Assessment Years : 2012-13 To 2017-18
section 68 of the Act needs to be applied for such escapement of income, however, while concluding the re-assessment proceedings the additions have not been made u/s.68 of the Act but have been made u/s.115BBC of the Act and therefore there is ‘change of opinion’ and no show cause notice/reasons/revised reasons recorded for initiating the re-assessment proceedings