TMI Blog2016 (2) TMI 971X X X X Extracts X X X X X X X X Extracts X X X X ..... been followed in CIT v. Software Consultants [2012 (2) TMI 18 - DELHI HIGH COURT ]. In sum, if no addition is made on the basis of the reasons to believe recorded by the Assessing Officer for reopening the assessment under section 148 of the Act, resort cannot be had to Explanation 3 to section 147 of the Act to make an addition on any other issue not included in the reasons to believe for reopen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xemption) [2015] 37 ITR (Trib) 512 (Delhi)) for the assessment year ( AY ) 2003-04. 4. The question sought to be urged by the Revenue is whether the Income- tax Appellate Tribunal was correct in quashing the notice issued under section 148 of the Income-tax Act, 1961 ( Act ) for reopening the assessment. 5. The reasons to believe recorded by the Assessing Officer ( AO ) for issuance of the n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t based on the accommodation entries which formed the subject matter of the reasons to believe for issuance of the notice under section 148 of the Act. 7. Against the order dated September 2, 2011, of the Commissioner of Income-tax (Appeals) dismissing the assessee's appeal, the assessee approached the Income-tax Appellate Tribunal which accepted the plea of the assessee that the reassessme ..... X X X X Extracts X X X X X X X X Extracts X X X X
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