2017 (7) TMI 775

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....udgment and order dated 22nd April, 2016 passed by Income Tax Appellate Tribunal, Lucknow Bench ''B', Lucknow (hereinafter referred to as the "Tribunal") in Income Tax Appeals No. 504 and 505/LKW/2015 filed by Assistant Commissioner of Income Tax, Central Circle - II, Lucknow ( hereinafter referred to as "Revenue") against Assessee - Respondent M/s Jai Prakash Associates Ltd., relating to Assessment Year (hereinafter referred to as "A.Y.") 2007-08 and 2008-09. Tribunal by means of impugned judgment has dismissed both the appeals. 3. The facts in brief relating to two assessment years are stated in brief as under : - A.Y. 2007-08 4. Assessee filed return of income on 31st October, 2007 at total income of Rs. 6,04,39,68,520/- a....

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....A.Y. 2007-08 and Rs. 92,22,86,740/- in relation to A.Y. 2008-09. 8. Both these orders passed by A.O. under Section 148/143 dated 30th March, 2014 were taken in appeal before Commissioner of Income Tax ( Appeals)-III, Lucknow ( hereinafter referred to as "CIT(Appeals)-III"). Vide orders dated 30th April, 2015, both the appeals were allowed by CIT(Appeals)-III holding that there is no ground for reopening the matter under Section 147 and, in fact, A.O. has reviewed assessment orders already made final though it has no power of such review. CIT(Appeals)-III, therefore, set aside the proceedings initiated under Section 147 of Act, 1961. Revenue filed two appeals before Tribunal but confirming order of CIT(Appeals)-III, Tribunal has dismissed b....