TMI Blog2008 (11) TMI 747X X X X Extracts X X X X X X X X Extracts X X X X ..... nder section 263 of the Income-tax Act, 19651 (hereinafter referred to as 'the said Act') is in issue in this appeal. In this case, the provision of section 263 of the said Act had been invoked by the Commissioner after reassessment proceedings under section 147 had been concluded by the Assessing Officer. It has been pointed out that the reasons for reopening the assessment were the very ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reason to interfere with the decision of the Tribunal. It may also be noted that in similar situations, orders passed by the Commissioner of Income-tax under section 263 have been set-aside by the Tribunal and upheld by this Court in the cases of CIT v. Vikram Aditya Associates (P.) Ltd. [2006] 287 ITR 268 1 and CIT v. Prudent Advisory Services (P.) Ltd. [IT Appeal No. 170 of 2007, dated 28-2-20 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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