TMI Blog2022 (1) TMI 142X X X X Extracts X X X X X X X X Extracts X X X X ..... opers [ 2021 (8) TMI 1267 - ITAT DELHI] following the case of Sam Portfolios Pvt. Ltd. (supra) held that the order of the CIT (Appeals) under Section 264 of the Act and notice u/s 148 of the Act has been issued exactly on same reasons recorded for reopening the assessment, therefore, the reassessment order cannot be sustained and same was quashed. Since the Tribunal in two case exactly on same set of facts had quashed the assessment passed under Section 147 therefore, respectfully following the same in this case also the assessment order passed by the Assessing Officer under Section 147 of the Act is quashed. The Cross Objection filed by the assessee is allowed and the appeal filed by the Revenue is dismissed. - ITA. No. 6225/Del/2015 an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... either conducting her own independent and effective inquiry nor giving a direction as per sub-section 4 of section 250, Income Tax Act and ignoring Hon'ble Delhi High Court's judgment in the case of The Commissioner of Income Tax - II Vs M/s. Jansampark Advertising and Marketing (P) Ltd. 5. (a) The order of the Ld. CIT(Appeals) is erroneous and not tenable in law and on facts. (b) The appellant craves leave to add, alter or amend any/all of the grounds of appeal before or during the course of the hearing of the appeal. C.O. No. 467/Del/2015: 1. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in framing impugned reasses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der Section 264 of the Act before the Commissioner of Income Tax, Central-II, New Delhi, who vide order dated 25.03.2014 declared the assessment order null and void. Now after the assessment order was declared null and void, the ld. Assessing Officer has reopened the case under Section 147 of the Act vide notice dated 29.03.2014 on the same issues and thereafter the Assessing Officer again completed the assessment at the same figure of ₹ 8,35,17,965/-. 6. The ld. CIT (Appeals) allowed the appeal of the assessee on merits holding that assessee has filed complete details of debits and credits appearing in the bank account and also the details of loan paid and interest earned there from. The assessee has also given entire details of n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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