2026 (7) TMI 279

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....e Appellant : Shri Ajay R Singh, Advocate For the Respondent : Shri Ganesh R Ghale, Standing Counsel for the Dept. ORDER PER WASEEM AHMED, ACCOUNTANT MEMBER: The present appeal has been filed by the assessee against the order of the learned CIT(A) passed under section 250 of the Income-tax Act, 1961 ("the Act"), dated 24.09.2025, relating to A.Y. 2015-16. 2. In Ground No. 1, the ass....

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....dgment of the Hon'ble Bombay High Court in the case of CIT vs. Jet Airways (I) Ltd. reported in 331 ITR 236. 3.2 On the other hand, the learned Departmental Representative (DR) strongly supported the orders of the lower authorities. 4. We have heard the rival submissions of both the parties and perused the materials available on record. The Hon'ble Bombay High Court in the case of CI....

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.... read these words as being in the alternative would be to rewrite the language used by Parliament. Our view has been supported by the background which led to the insertion of Explanation 3 to section 147. Parliament must be regarded as being aware of the interpretation that was placed on the words "and also" by the Rajasthan High Court in Shri Ram Singh's case (supra). Parliament has not taken....

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....o addition is ultimately made on the very reason for which jurisdiction under section 147 of the Act was assumed, then no other addition can be sustained in the reassessment order. 4.2 In the facts of the present case, there is no dispute that the reassessment proceedings were initiated on account of the difference between the sale consideration adopted for stamp duty purposes and the considera....