2016 (7) TMI 821

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....total income of Rs. 8,39,253/- was filed on 31.10.2006, which was processed u/s 143(1) of the Income-tax Act, 1961 (hereinafter also called `the Act'). Assessment order u/s 143(3) of the Act was passed on 26.3.2008 determining total income at Rs. 8,56,753/-. The AO reopened the assessment by noticing that the assessee claimed credit for TDS against the current year's income on receipts of Rs. 4,47,600/-, which were not offered for taxation. Assessment was completed u/s 147/143(3), making total addition of Rs. 2,37,500/-. The assessee, inter alia, argued before the ld. CIT(A) that the AO had issued notice u/s 154 and hence the initiation of reassessment proceedings by means of notice u/s 148 was not valid. The ld. CIT(A) remained unconvinced....

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....iced that the AO earlier issued notice u/s 154 dated 23.2.2011, a copy of which is available at page 25 of the paper book, indicating the mistake in the assessment order, which reads as under:- "The CAG audit noticed that as per TDS certificates and bifurcation of the total professional receipts filed during the course of assessment proceedings the following receipts received from the following parties were not found to have been included in the total receipts which have credited to the P&L account. S.No. Name of the party Total professional receipts received as per TDS certificate (in Rs.). 1. Bhilwara Chittorgarh Duss Ltd. 45,100/- 2. Murgan Securities Credits 95,000/- 3. Goyal M.G. Gases (P) Ltd. 2,49,000/- 4. Khaitan Chem....