1161/Del/2024
Naveen Kumar Singhal vs ITO
the assessee was re-opened under s. 147 of the Act by issuing notice under ... thereby, re-
opening of the concluded assessment, re-assessment proceedings were set
motion. The AO alleged that aggregate
proceedings under Section 147 were
initiated and set in motion. In the course of the re-assessment proceedings, the
Assessing Officer however issued a corrigendum
month to HBO PP.
• Prov ision of product and pro motion al licensing
serv ices f or certain "car toon char acters ... 1204/Del/2018 6
Product and Pro motional licensing f ee
In teres t on ECB
Cost re imburse ments received.
1.2.7 Based
Learned Asse ssing Officer's
re-assessment framed herein on 27.12.2016 indic ates tha t he
thereafter finalized section ... asse ssed, had escape d assessment. He accordingly
set into motion the impugned re-opening by issuing sectio n 148
notice dated 29.03.2016. All this
after the re-assessment order has been framed, a minimal inquiry by
the Pr.CIT was incumbent before setting aside the re-assessment
order ... proceedings sets in motion on receipt of new
material (communication to Assessing Officer post re-assessment)
coming on record post assessment and hence the responsibility
either the Company on its own motion or the depositors had moved to the High Court for re-fixation of the rate of interest ... Shri Syali, the counsel for the assessee in his re-direct submitted that the Bombay High Court in Chase Bright Steel
Section 139 (8) of
the Act at the time of re-assessment proceedings which was
apparent from record. Hence, the Assessing Officer rectified the
same ... time of passing of re-
assessment order. The Assessing Officer was competent to make
amendment/rectification in the re-assessment order as per Section
Petronet Lng Ltd., New Delhi vs Addl. Cit, New Delhi on 18 March, 2021
IN
were set in motion. In pursuance to the notice issued u/s 153A of the Act,
the assessee filed ROI and re-iterated the total
Swiss Ba n k a cco un t a re not su sta ina b le an d shou ld b e d eleted ... eith er b efo re o r a t the time o f
h ea rin g ."
3. The case has a chequered history
