2025 (3) TMI 1977

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....nd or grounds of appeal are without prejudice to one another. 1.a) On the facts and in the circumstances of the case and in law, the ld. CIT(A) erred in confirming the action taken by the AO in re-opening the assessment u/s.147 of the Income Tax Act, 1961 though the prescribed conditions therein are not satisfied. b) The Id. CIT(A) failed to appreciate that initiation of re-opening of assessment proceedings and completion of the re-assessment u/s.147 r.w.s. 144B by the AO is without jurisdiction and bad in law. 2.a) On the facts and in the circumstances of the case and in law, the Id CIT(A) erred in confirming the addition of 7 1,54,421/- made by the AO to the income of the Appellant on account of difference in in....

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.... levy of interest u/s.234C and initiation of penalty proceedings u/s.271(1)(c) respectively without passing any speaking order. The Appellant denies its liability for such interest and penalty. The Appellant craves leave to add, alter, amend or delete any or all of the above grounds of appeal." 3. The assessee has challenged the reopening of the assessment u/s 147 of the Act by not following the prescribed conditions mentioned in the relevant provisions of the Act. 4. It has been strongly argued that the approval has been granted by the Authority in the old provisions of the Act relating to the approval and notice u/s 148 of the Act following the decision in the case of Union of India vs. Ashish Agarwal reported in 444 ITR 1 ....