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2019 (8) TMI 1616
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....A of the Income-tax Act, 1961 (the 'Act'), challenges the order dated 9 December, 2015 passed by the Income Tax Appellate Tribunal, Mumbai ('Tribunal'). This Appeal relates to Assessment Year 2004-05. 2. Mr. Suresh Kumar, learned counsel for the Revenue urges the following two questions of law for our consideration: "(i) Whether the Tribunal was correct in holding that ....
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....tion. However the Assessing Officer did not accept the Respondent's contention and passed an order of assessment under section 143(3) r.w. section 148 of the Act. (b) In appeal, the Commissioner of Income Tax (Appeals) held that the reopening notice had been issued without having recorded the reasons which led the Assessing Officer to form a reasonable belief that income chargeable to tax e....
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....und an entry as regards issue of notice under section 148 dated 6 March, 2009. However no entries prior thereto i.e. 6 March, 2009 were produced before the Tribunal, so as to establish that the reasons were recorded prior to the issue of notice dated 6 March, 2009 u/s. 148 of the Act. Thus the Tribunal concluded that prior to 6 March, 2009 there is nothing in the record which would indicate that a....