2017 (12) TMI 1399

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....ces of the case and in law, the ld. CIT(A) erred in holding that the assessment completed u/s. 147 is bad in law. 2. On the facts and in the circumstances of the case and in law, the ld. CIT(A) erred in holding that the assessment completed u/s. 147 is bad in law without taking into consideration that if a single valid reason is available for reopening the assessment u/s. 147, the assessment is valid. 3. The grounds raised in the assessee's cross objection read as under: CO No.1: Addition of dividend income 1.1. On the facts and in the circumstances of the case and in law, the Learned Commissioner of Income Tax (Appeal) ('CIT(A)') erred in not adjudicating ground number 2 of the appeal before him which pertained to addition o....

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....rned CIT(A) erred not appreciating the fact that a rectification application under section 154 of the Act was pending before the AO with respect to the restructuring cost for amalgamation. CO No.5: Levy of Interest: 5. On the facts and in the circumstances of the case and in law, the ld. CIT(A) erred in upholding the action of the A.O. in levying interest under Section 234B, 234D and Section 220 of the Act. 4. The issue raised in the Revenue's appeal and the issue raised in cross objection read as under: In this case the assessment was reopened as assessment framed u/s. 143 r/w s. 147 of the Act. In the above assessment order, the Assessing Officer added the following: Computation of Total Income: Total income as per order dated 30....