2025 (9) TMI 1136

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.... on the facts and circumstances of the case and in law, whether the Hon'ble ITAT erred in upholding the order of the CIT(A) that the reopening of assessment was bad in law as no 'tangible' incriminating material was found during the survey proceedings for A.Y. 2006-07, without having regard to the fact that during the survey proceedings, the assessee failed to establish the genuineness of the expenditure in question. The findings of the survey proceedings, was the material/evidence for reopening the assessment ? ii. Whether on the facts and circumstances of the case and in law, whether the Hon'ble ITAT erred in not appreciating the fact that the alleged service provider did not have the required infrastructure, manpower and experti....

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....jections to the said reasons which were disposed of by the Assessing Officer by his letter dated 13.01.2014. Accordingly, the Assessing Officer proceeded for reassessment under Section 143(3) read with Section 147 of the IT Act. The reassessment was completed on 28.03.2014. 4. Being aggrieved by the order passed by the Assessing Officer, the Assessee Company preferred an Appeal before the CIT (Appeals). The CIT (Appeals), after hearing the parties, held that reassessment was improper and invalid. Accordingly, the Assessee was granted relief on various additions made by the Assessing Officer. 5. Being aggrieved by the order of the CIT (Appeals), the Revenue approached ITAT. The ITAT, after hearing the Revenue representative as well as ....