2017 (9) TMI 671

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....or Standing Counsel ORDER 1. The challenge in this Petition is to the notices dated 18th March 2015, 24th March 2015 and 18th January 2016 issued by the Deputy Commissioner of Income Tax ('DCIT') (hereafter Assessing Officer- AO) under Section 148 of the Income Tax Act, 1961 ('Act') seeking to reopen the assessment for the Assessment Year ('AY') 2008-09. Challenge is also laid to the order dated....

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....sment in the present case, the AO recorded that the Assessee was allowed to set off brought forward losses of Rs. 5,32,18,761/- whereas, according to the AO, as per the assessment records of the AY 2007-08, "no loss was available for set off in subsequent year" as the Assessee-company was assessed at an income of Rs. 19,73,01,700/- in AY 2007-08. Without indicating the manner in which there was fa....