9911796707
TMI Blog2024 (10) TMI 1274X X X X Extracts X X X X X X X X Extracts X X X X ..... RJIT SINGH, ACCOUNTANT MEMBER: This appeal of the Revenue for the assessment year 2017-18 is directed against the order u/s 250 of the Income-tax Act, 1961 dated 19.06.2024 passed by the ld. Commissioner of Income-tax (Appeal), National Faceless Appeal Centre, Delhi. 2. Facts in brief are that the return of income declaring the total income of Rs. 16,42,210/- was filed for the year under conside ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 92,12,500/- was treated as 'Income from other sources' u/s 56(2)(vii)(b) of the Act and added to the total income of the assessee vide order u/s 143(3)/147 passed on 29th May, 2023. 3. Aggrieved, the assessee filed appeal before the ld.CIT(A). 4. The ld.CIT(A) has allowed the appeal of the assessee after following the decision of the Hon'ble High Court of Bombay in the case of the assessee in W. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ourt in the case of Siemens Financial Services Private Limited Vs. DCIT and others reported in (2023) 457 ITR 647 (BOM) had held that the proceedings are invalid, in view of the invalid sanction and hence has to be quashed. According to the Hon'ble Court, in the case under consideration, the assessment year is AY 2017-18 and when the same falls beyond the period of 3 years, the sanction ought ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h the sides and perused the material on record. We have perused the copy of the order of the Hon'ble jurisdictional High Court of Bombay in the case of the assessee vide W.P. (L) No.15147 of 2024 dated 06th May, 2024, wherein the assessment has been quashed because of invalid sanction obtained u/s 151 (ii) and not u/s 151(i) of the Act as discussed, supra, in the findings of the ld.CIT(A). Therefo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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