TMI Blog2010 (1) TMI 1224X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee is directed against the order dated 5th September, 2005 of the CIT(A)-XIX, Mumbai relating to assessment year 2002-03. 2. In grounds of appeal No. 1, the assessee has challenged the order of the CIT(A) in upholding the validity of reopening of assessment u/s. 147/148 of the Income-tax Act, 1961 (the Act) made by the Assessing Officer. The learned counsel for the assessee did not pres ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal No. 3, the assessee challenged the order of the CIT(A) in holding that the licence fees are not chargeable to tax under the head Income from other sources . The learned counsel for the assessee fairly conceded that this ground is also against the assessee by the decision of the Hon ble Supreme Court in the case of Shambhu Investments (supra). In view of the above submission by the learned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f appeal No. 6 relates to initiation of penalty proceedings. After hearing both the sides, we are of the considered opinion that this ground is premature in nature and therefore, we dismiss this ground. 9. Grounds of appeal No. 7 by the assessee being general in nature is dismissed. 10. In the result, the appeal filed by the assessee is dismissed. Order pronounced on 22nd January, 2010. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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