TaxTMI 
TaxTMI 
2022 (5) TMI 1658
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.... as it confirms the addition made by the Assessing Officer. (2) That the Learned Commissioner of Income Tax, (Appeals) has grossly erred in confirming the assumption of jurisdiction u/s 147/148 of the Act, by the AO which jurisdiction is illegal and bad in law. (3) That the order passed pursuant to illegal assumption of jurisdiction u/s 147/148 of the Act is void ab initio and deserves to be quashed. (4) That the Learned Commissioner of Income Tax, (Appeals) has grossly erred in confirming an addition of Rs.57,39,306/- for alleged bogus purchase made from M/s. Naman Exports without appreciating the fact that the purchased diamonds had been exported out of India and an independent government agency had verified the fact of exports. ....
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....laring total income of Rs.3,74,820/-. Notice u/s 148 of the Income Tax Act, 1961 for reopening the above assessment was issued on 17.03.2015 and was served on the assessee on 19.03.2015. 4. Reasons recorded on 17.03.2015 for re-opening the assessment has been duly provided vide letter dated 13.07.2015 to the assessee. The reasons recorded are as under: Reasons recorded for re-opening the case of 147/148 of Income Tax Act "M/s Uma Strips. Ltd. is assessed to tax with Circle 27(1), New Delhi. The assessee company e-filed its Return of income on 28.09.2010 declaring total income of Rs. 3,74,820/-. The case was processed ids 143(1) of Income tax Act-1961. 2. Director of lnvestigation-11, Mumbai have unearthed huge accommodation entry r....
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....essary for its assessment, for the assessment year 2010-11. In view of the above facts, I have reasons to believe that income to the tune of Rs.57.39 Lakhs of the assessee company for A. Y. 2010-11, has escaped assessment." 5. At the outset, the ld. AR argued that the assumption of jurisdiction u/s 147 of the Income Tax Act, 1961 is void ab initio as there was no "satisfaction" drawn by the Assessing Officer. 6. The ld. DR argued that the "satisfaction" of the AO is apparent from the "reasons recorded" by the AO. 7. Heard the arguments of both the parties and perused the material available on record. 8. We find that, a. The first para deals with the factual information about filing of the return by the assessee and processing u/s 143....