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TMI Blog2018 (11) TMI 646X X X X Extracts X X X X X X X X Extracts X X X X ..... sessment year 2006-2007. This factual position is not disputed or factually challenged. AO had noticed this objection but did not dwell and specifically examine and answer the same in the re-assessment order. There was quietus on the said aspect by the Assessing Officer, who had impliedly admitted the factual position of full and true disclosure of material facts. This is not a case where infer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and good reason to reopen the concluded assessment. The Revenue has accepted the decision of the Commissioner of Income Tax(Appeals) on the second aspect and did not challenge this finding. - ITA 509/2018 - - - Dated:- 10-9-2018 - MR. SANJIV KHANNA AND MR. CHANDER SHEKHAR JJ. Appellant Through: Mr. Ruchir Bhatia, Advocate Respondent Through: Mr. Salil Kapor, Mr. Sumit Lalchandani ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessment were not satisfied. 3. It is an accepted and admitted position that the return filed by the respondent/assessee for the assessment year 2006-07 declaring loss of ₹ 14.53 crores, was made subject-matter of scrutiny assessment under Section 143(3) of the Act vide order dated 23.12.2010. Loss of ₹ 10.12 lacs was allowed to be carried forward. 4. The reasons to believe rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or factually challenged. Moreover, the Assessing Officer had noticed this objection but did not dwell and specifically examine and answer the same in the re-assessment order. There was quietus on the said aspect by the Assessing Officer, who had impliedly admitted the factual position of full and true disclosure of material facts. This is not a case where inference or interpretation on the basi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eals) had accordingly held that the ground would not be a valid and good reason to reopen the concluded assessment. The Revenue has accepted the decision of the Commissioner of Income Tax(Appeals) on the second aspect and did not challenge this finding. 6. In view of the aforesaid, we do not find any merit in the appeal and the same is dismissed in limine, with no order as to costs. - - Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X
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