2019 (4) TMI 1734

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....i, Sr. DR ORDER This is an appeal filed by the assessee against the order of Commissioner of Income Tax (Appeals)-7, New Delhi dated 12.09.2018. 2. The assessee has raised following grounds of appeal: 1) That having regard to the fact and circumstances of the case, Ld. CIT (A) has erred in law and on facts in confirming the action of Ld. AO in framing the impugned reassessment or....

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.... loans taken from M/s Prayag India (P) Ltd., and more so without appreciating the material on record & without observing principles of natural justice. 4) That in any case and in any view of the matter, action of Ld. CIT(A) in confirming the addition of Rs. 34,00,000/- is bad in law and against the facts and circumstances of case and without considering the material placed on record and b....

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....otice of reopening of assessment issued u/s 148(2) of the Act is bad in law and consequently the impugned reassessment order passed u/s 147 r.w.s. 143(3) of the Act is bad in law. 4. I have heard the rival submissions and perused the orders of lower authorities and material available on record. In the instant case, notice u/s 148 of the Act was issued to the assessee on 30.03.2017 by recording ....

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....HC) has held the mere appending of the expression "approved" says nothing, Commissioner of Income Tax has to record elaborate reasons for agreeing with the noting put up, and at the same time, satisfaction has to be recorded of the given case which can be reflected in the briefest possible manner. 8. I find that the approval was granted by the Pr. CIT-7, New Delhi by noting "Yes I am satisfied"....