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2021 (8) TMI 1267 - ITAT DELHIReopening of assessment u/s 147 pursuant to the order of the ld. CIT u/s 264 - Unexplained expenditure - HELD THAT:- In the case in hand, again pursuant to the order of the ld. CIT u/s 264 of the Act, notice u/s 148 of the Act was issued and served upon the assessee and reasons recorded for reopening the assessment are identical to the reasons recorded in the case of M/s Sam Portfolio Pvt Ltd[2020 (2) TMI 1142 - ITAT DELHI], though quantum may differ. On finding parity on the facts of the case in hand with the facts of the case of M/s Sam Portfolio Pvt Ltd [supra], we have no hesitation in adopting the findings given by this Tribunal in the case of M/s Sam Portfolio Pvt Ltd [supra] considered view that the AO has wrongly assumed jurisdiction in framing the assessment order u/s 143(3) r.w.s 147.
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