TaxTMI 
TaxTMI 
2024 (2) TMI 1684
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....ate Ms. Supriya Mehta, CA ORDER PER N. K. BILLAIYA, AM: This appeal by the revenue is preferred against the order of the CIT(A)- 16, Delhi dated 25.09.2014 pertaining to A.Y. 2007-08. 2. The solitary grievance of the revenue is that the CIT(A) erred in allowing the appeal of the assessee by holding that the proceedings initiated u/s.147 are bad in law. 3. 2 Briefly stated the facts ....
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....had debited preliminary expenses of Rs. 9,89,12,000/- under the head survey and investigation expenses written off in the profit and loss account. These expenses were deferred in 5 equal installments and after allowing 1/5th expenses of Rs. 1,97,82,400/- for the year balance expense of Rs. 7,91,29,600/- should have been disallowed. The mistake resulted in under assessment of income of Rs. 7,91,29,....
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....pening was challenged before the CIT(A) and the CIT(A) was convinced that the reasons recorded for reopening the assessment are nothing but change of opinion and accordingly held the reopening is bad in law. 5. Before us the DR strongly supported the findings of the AO and in his written submission relied upon seven decisions of Hon'ble High Courts. 6. The Counsel for the assessee heavily re....