2015 (12) TMI 773

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....mar, Advocate, Mr. Dileep Shivpuri, Advocate and Mr. Sanjay Kumar, Advocate. ORDER CM APPL No. 22567 of 2015 (for condonation of delay) in ITA No. 768 of 2015 CM APPL No. 22568 of 2015 (for condonation of delay) in ITA No. 769 of 2015 1. For the reasons stated in the applications, the delay in refiling the appeals is condoned. 2. The applications are disposed of. ITA No. 768 of 2....

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....w, in at least in two aspects. One was that the reopening was of assessment beyond four years after the AY for which the original assessment was framed and yet the reasons for reopening did not categorically state that there was a failure by the Assessees to disclose any material particulars on the basis of which there were reasons to believe that the income has escaped assessment. This Court has ....

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....on. 7. The Court is of the view that notwithstanding several decisions of the Supreme Court as well as this Court clearly enunciating the legal position under Section 147/148 of the Act, the reopening of assessment in cases like the one on hand give the impression that reopening of assessment is being done mechanically and casually resulting in unnecessary harassment of the Assessee. 8. The ....