2025 (10) TMI 23

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....red to as 'the Act'). 2. Heard both the parties at length. Case file perused. 3. The assessee pleads the following substantive grounds in the instant appeal: 1. That the L'd Commissioner of Income Tax (Appeals) has erred on facts and law in sustaining the reassessment proceedings U/S 147 initiated second time beyond four years. She has further failed to appreciate the Jurisdictional High Court's latest view and has bypassed the law on the subject very discreetly. 2. That the L'd Commissioner of Income Tax (Appeals) has misunderstood the ground of appeal challenging addition of Rs 2,30,00,000/- and has without a speaking order dismissed the ground as non-maintainable, thereby sustaining the aforesaid addition U/S 68 which ....

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.... to believe that the assessee's taxable income liable to be assessed as escaped assessment. 5. It is in this factual drop that Mr. Sampat has invited our attention to the learned Assessing Officer's reopening reasons recorded at page 30 of the paper-book reading as under: "REASONS FOR ISSUE OF NOTICE U/S 148 IN THE CASE OF M/S MODINAGAR ROLLS LIMITED, MAJOR ASHA-RAM TYAGI ROAD, MODINNAGAR, PAN AABCM0137C FOR ASSESSMENT YEAR 2009- 10- The assessee is a limited company specializing in the line of manufacturing rolls for various industries. In this case, an information had received from DIT(Inv.)- 11. ARA Centre Jhandewalan Extn. New Delhi regarding accommodation entries provided by Shri Surendra Kumar Jain, Group of cases to beneficiary....