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TMI Blog2015 (10) TMI 809X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer (‘AO’), there is no satisfactory explanation for the extraordinary delay. There appears to be some casualness on the part of the counsel for the Revenue in attending to the defects pointed out by the Registry. Consequently, the Court is not inclined to condone the delay in re-filing the appeal.- Decided against revenue. Reopening of assessment - whether the ITAT was justified ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... spectively. This meant that the AO was himself “not sure that the entire amount which was mentioned in the report of the investigation was on account of the escaped income of the Assessee.” This also showed that the AO had not applied his mind before issuing notice under Section 148 of the Act. No substantial question of law arises for determination - Decided against revenue. - I.T.A. No. 226 of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e same. Since the Appeal have been filed in the discharge of the official duties and on the basis of the records maintained in the office, there has been some delay in re-filing the Appeal. The delay of 344 days in re-filing the appeal may be condoned as the Appeals are being filed in the discharge of the official duties and some delay has taken place on account of fact that the concerned officer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re-filing the appeal. 5. Nevertheless, appeal has also been examined on merits. The question urged for consideration is whether the ITAT was justified in quashing the reassessment proceedings under Section 147/148 of the Income Tax Act, 1961 ( Act ) on the ground that there was no specific material with the AO to hold that any income has escaped assessment. 6. The decision of the ITAT appears t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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