TMI Blog2017 (8) TMI 180X X X X Extracts X X X X X X X X Extracts X X X X ..... ing for source of source can be relevant inquiry. - Decided against the assessee - GA 409 of 2016, ITAT 103 of 2016 - - - Dated:- 24-3-2017 - Aniruddha Bose And Arindam Sinha, JJ. For the Petitioner : Mr. B. K. Singh, Adv For the Respondent : Md. Nizamuddin, Adv ORDER The Court :- This is assessee s appeal against an order dated 10th August, 2015 of the Income Tax Appellate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty had passed the order under Section 263 of the Act after a reassessment exercise was undertaken by the assessing officer in a proceeding under section 147/143(3). Such reassessment proceeding was actually triggered off by the assessee by disclosing certain sum of money which it contended had escaped assessment in the regular assessment procedure. Stand of the assessee is that the Revisional Auth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y held companies under certain circumstances. The Tribunal found the amendment to Section 68 of the Act to be retrospective in operation. The assessee is before us challenging legality of the order of the Tribunal on this ground, and certain other points have also been urged to assail the Tribunal s order. The core issue involved in this appeal had earlier arisen before this Court and in a judg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by us on 23rd March, 2017, we took the same view, and we also held that the position of law would not change in the event such infusion of capital at a high premium was effected in the first year of business or year of commencement of business of the assessee. No other point has been urged before us by the appellant. In our opinion, the present appeal is covered by our decision in Pragati an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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