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1 - 10 of 17 (0.26 seconds)Section 147 in The Income Tax Act, 1961 [Entire Act]
Section 153A in The Income Tax Act, 1961 [Entire Act]
Section 132 in The Income Tax Act, 1961 [Entire Act]
Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 234C in The Income Tax Act, 1961 [Entire Act]
Commissioner Of Income Tax-5 vs Jet Airways (I) Ltd. on 12 January, 2015
In this regard, Learned Authorised
Representative for the Assessee relied upon the decision of the
Hon‟ble Bombay High Court in the case of CIT vs. Jet Airways (I)
Ltd.: 331 ITR 236 wherein it was held that when no addition has
been made qua any of the item for which reasons were
recorded for reopening the assessment under Section 147 of the
Act, no further additions can be made in the reassessment
proceedings and therefore, the reassessment fails. On the
strength of the aforesaid judgment, the Ld. Authorised
Representative for the Assessee submitted that the ratio of the
aforesaid judgment is equally applicable to proceedings under
Section 153C of the Act. Since in the facts of the present case
no addition was made on account of unexplained portion of
jewellery found/seized during the search proceedings in the
hands of the Assessee, the satisfaction recorded should be held
8
ITA Nos. 3917-3921/Mum/2019,
ITA Nos. 3924-3928/Mum/2019,
ITA Nos. 4120, 4122, 4123 & 4114/Mum/2019
to be invalid and the assessment order under Section 153C read
with Section 143(3) of the Act must be quashed.