2017 (12) TMI 64

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..... nbsp; 1. The Revenue's grievance in this case is that its appeal is rejected by the Income Tax Appellate Tribunal (ITAT) on the ground that the tax effect is lower than the stipulated amount in terms of the prevailing Circular. The assessments involving similar questions were remitted for fresh consideration to the Commissioner of Income Tax (Appeals) in the case of other parties, i.e. Mr. Arvind .....

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..... oceedings under Section 148 were initiated culminating by substantial acceptance of the Assessee's arguments and not resulting in any noticeable addition - by an order dated 31.12.2007. The Assessee has produced the copy of that Assessment Order. It refers to a letter of the Directorate of Enforcement dated 28.03.2006, mentioning about some transactions by the Assessee. The Revenue appears to have .....

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..... nces received are not considered in the return of income filed by the Assessee and in the course of the assessment proceedings for the Assessment Years 2003-2004 & 2006-2007". That clearly shows that the A.O. ignored that the material, which led the Revenue to re-open the Assessment, in the first instance, was the same that he sought to resuscitate in order to make substantial additions. 7. Havin .....

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