2025 (1) TMI 576

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....ome Tax Appellate Tribunal (hereafter the ITAT) whereby the appeal preferred by the respondent (hereafter the Assessee) being ITA No. 605/Del/2023 in respect of the assessment year (AY) 2013-14 against the final assessment order dated 24.01.2023 passed under Section 147 of the Act, was allowed. 2. The Assessee had filed the said appeal raising several grounds, however, the same was allowed by the learned ITAT on the sole ground that the reopening of the assessment was without the application of mind. The learned ITAT referred to its earlier decision in the case of M/s. Cricket South Africa (Association) in ITA No. 604/Del/2023 whereby the appeal of that assessee was allowed on a similar ground. 3. This court is informed that the appeal pr....

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....ht of this, the genuineness of financial transaction/business activity of this company could not be ascertained. 4. Thus from the above discussion, it is clear that the incomes during FY 2012-13 has escaped assessment in India as M/s. Cricket Australia has not filed return in India for A.Y. 2013-14. 5. In view of the above, I have reason to believe that the income during the FY 2012-13 relevant to A.Y. 2013-14 has escaped assessment as defined u/s. 147 of the Income-Tax Act, 1961. Accordingly, notice u/s. 148 of the Act may be issued in this case. 6. In this case, the only requirement to initiate proceedings u/s. 147 is reason to believe which has been recorded above. This case is beyond four years & within six years from the end of t....