2018 (2) TMI 1780

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....ion 260A of the Income Tax Act, 1961 (the Act) challenges the order dated 6th February, 2015 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order is in respect of Assessment Year 2004-05. 2. The Revenue has urged the following question of law for our consideration : Whether on the facts and circumstances of the case and in law, the Tribunal was justified in holding tha....

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....s recorded in support of the reopening notice as forming its reasonable belief that income chargeable to tax has escaped assessment. 4. In the above view, the question as formulated becomes academic as our Court in Commissioner of Income Tax Vs. Jet Airways (I) Ltd. 331 ITR 236 while examining Explanation3 to Section 147 of the Act has held that the Assessing Officer has to necessarily assess / r....