2026 (3) TMI 683

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....reet Kaur Hansra, Sr. DR ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER This assessee's appeal for assessment year 2010-11, arises against the Commissioner of Income Tax (Appeals)-23, [in short, the "CIT(A)"], Delhi's appeal Nos. 53 & 54/2019-20, dated 27.09.2019 involving proceedings under section 147/148 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). Case called....

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....fficer had completed his section 143(3) r.w.s 148 assessment in the assessee's case on 28.03.2018. There is further no denial to the clinching fact that the impugned reopening reasons nowhere even alleged the assessee failure in disclosing all necessary facts "fully" and "trully" in the above former round. We are of the considered view in light of Hindustan Lever Limited Vs. R.B. Wadkar (2004) 268....