2015 (11) TMI 1290

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....ssessee against the consolidated order of Commissioner of Income Tax (Appeals), Dhanbad, dated 31/03/2014 passed in the assessment years 2006-07 to 2008-09. 2. In all the years under consideration, the sole issue involved is that Commissioner of Income Tax (Appeals) was not justified in confirming the action of the Assessing Officer in initiating the proceedings under section 148 of the Act. 3. ....

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....very specific information leading to belief that income chargeable to tax had escaped assessment and proceedings under section 147 of the Income-tax Act, 1961were initiated. The appellant made no compliance initially and later submitted that returns filed earlier may be treated as returns filed in response to such notices. Thereafter, the AO duly issued notices under section 143(2) and 142(1) of t....

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....which fact has been accepted by the Commissioner of Income Tax (Appeals) in his order. Relying on the decision of the Hon'ble Bombay High Court in the case of CIT vs. M/s. Trend Electronics reported in - 2015-TIOL-2393-HCMUM-IT he submitted that the Hon'ble High Court has held that when an order is passed in re-assessment proceedings in absence of reasons recorded for issuing a re-opening ....