TMI Blog2021 (2) TMI 173X X X X Extracts X X X X X X X X Extracts X X X X ..... rder would be erroneous only when the assessing officer makes no enquiries during the course of the assessment proceedings. In the present case the tribunal found as a fact that the Principle of Mutuality had been examined threadbare by the assessing officer itself and therefore it was not a case where the Commissioner could have exercised jurisdiction under Section 263 of the said Act. In these ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1 of the I.T. Act, 1961. The A.O, however, discussing in detail the activities of the assessee, rejected the claim of assessee for exemption under section 11 of the I.T. Act, 1961. The A.O. further held that its income other than interest income amounting to ₹ 75,73,939/- covered under principle of mutuality and treated it as non-taxable. Thus, assessment in this case was completed under sec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that Revenue filed Departmental Appeal before Hon ble Delhi High Court which is dismissed vide Order Dated 06.02.2017 in ITA.No.26/2017. The Ld. CIT(A), therefore, noted that since the Order under section 263 on the basis of which the impugned assessment order under section 143(3)/263 was passed has been cancelled by the Tribunal and Departmental Appeal have been dismissed by the Hon ble Delhi Hi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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