2023 (2) TMI 747

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.... present appeal filed by the assessee for the assessment year 2009- 10 is directed against the order of Ld. CIT(A)-43, New Delhi dated 24.08.2018. The assessee has raised following grounds of appeal:- 1. "On the facts and in the circumstance of the case and in law the CIT(A) was incorrect and unjustified i. In dismissing the appeal of the assessee. ii. In holding that action taken by the ....

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....olding action u/s 147 as illegal and bad in law when the condition necessary as provided in first proviso to section 147 regarding failure to disclose fully and truly all material facts in the reason itself is not satisfied. 3. On the facts and in the circumstance of the case and in law the CIT(A) was incorrect and unjustified in not holding initiation of action u/s 147 is illegal and bad in la....

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....to be sold during the same assessment year and also found entered in the Stock Register. 6. On the facts and in the circumstance of the case and in law the CIT(A) was incorrect and unjustified in holding that the assessee had not made purchase from Tirupati Trading Company even when the audited books of account have not been rejected and no discrepancy found and on the contrary book results hav....

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....acts giving rise to the present appeal are that return of income was electronically filed on 30.09.2009, declaring a loss of Rs.7,05,37,007/- which was assessed u/s 143(3) of the Income Tax Act, 1961 ("the Act") at a loss of Rs.6,38,57,040/- on 30.12.2011. Thereafter, the assessment was re-opened u/s 147 of the Act on the basis of escapement of income amounting to Rs.48,22,500/-. The assessment wa....