2025 (3) TMI 2182

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....Neha Paranjpe, A/Rs For the Revenue : Shri Ram Krishn Kedia, Sr. D/R ORDER PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the assessee is preferred against the order dated 30/09/2024 by NFAC, Delhi [hereinafter "the ld. CIT(A)"], pertaining to AY 2014-15. 2. The assessee has challenged the re-opening u/s 147 of the Act and has also challenged the merits of the additions made. The a....

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....ntravention of the procedure prescribed by the Hon'ble Supreme Court in the case of GKN Driveshaft (Supra). Thus, the notice under section 148 of the Act and the subsequent reassessment order passed under section 143(3) r.w.s 147 of the Act are bad in law and without jurisdiction and the same needs to be quashed." 3. Since the additional grounds raised, go to the root of the matter, we deci....

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....und to dispose of the same by passing a speaking order. The Hon'ble High Court of Bombay in the case of Asian Paints Ltd. vs Deputy Commissioner of Income- Tax [2008] 296 ITR 90(Bom), has held that "the assessee must be given a reasonable period of about four weeks to take any remedial course of action should the assessee's objections to the reopening be rejected by the revenue." 6. Facts on re....