TMI Blog2017 (12) TMI 64X X X X Extracts X X X X X X X X Extracts X X X X ..... relevant facts and accepted the net income at ₹ 1,03,890/- . The assessment made in the course of assessment proceeding, in the present case, does not refer to any subsequent material other than the Directorate of Enforcement’s letter of 28.03.2006; instead the A.O. appears to have just made a Chart as the basis even while acknowledging that the earlier re-assessment proceedings were conclu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 Khanna and Mr. Navin Khanna. 2. The Revenue urge ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 issued a fresh notice under Section 148 on 23.02.2012 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. Having regard to these facts, the Court is of the opinion th ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
