2023 (1) TMI 1390

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....Amit Sharma , Adv. ..for the appellant Mr. Ajay Gaggar , Adv. Mr. Hiranyak Gangopadhyay , Adv. ...for the respondent ORDER GA/1/2022 The Court : - Heard respective Counsel for either side. There is a delay of 378 days in filing the appeal. From the relevant dates we find that the appellant department would be entitled to the benefit of the order passed by the Hon'ble Supreme Court extending....

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....s and circumstances of the case and in law, the Learned Income Tax Appellate Tribunal has erred in quashing the reopening of assessment order under section 148 of the Act as bad in law thereby deleting the addition made on the basis of disallowance of Rs.6,92,90,000/- claimed on account of Provision of VAT ? iii) Whether in the facts and circumstances of the case and in law the Learned Tribunal ....

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....ent. We have perused the reasons for reopening which have been extracted in the assessment order dated 21.1.2016 passed under Section 147 read with Section 154 and Section 143(3) of the Act. From the reasons it is evidently clear that material already available in the books of accounts have been re-apprised by the assessing officer and notice under Section 148 has been issued. The manner of such ....