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TMI Blog2018 (2) TMI 1944X X X X Extracts X X X X X X X X Extracts X X X X ..... ption of tangible material unavailable with the Revenue at the time the original assessment was completed. Furthermore, in the present case, the original assessment was not completed under Section 143(3) of the Act, rather, merely framed under Section 142(1) of the Act. Having regard to these facts, the impugned order is clearly untenable and set aside. ITAT is directed to examine the merits ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r Section 143(1) of the Income Tax Act, 1961 (hereinafter referred to as the Act ) for the A.Y. 2006-07, on 30.03.2007. Based upon information received, a notice was issued to the respondent assessee proposing re-assessment under Section 147 of the Act on 19.03.2013. The Reasons to believe supplied to the respondent assessee disclosed that the rationale for re-assessment was fresh information a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubject mentioned above. 1. The assessment of search cases of Sh. Rakesh Gupta, Sh. Vishesh Gupta, Sh. Navneet Jain Sh.Vaibhav Jain are under process with the ACIT, Central Circle 10. During the assessment proceedings u/s 153A in the aforesaid cases, details regarding accommodation entries given by the above entry. 2. This list of accommodation entry recipients ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the information in respect to annexure A, B and C is also enclosed. 5. The information of accommodation entry includes AY 2006-07 also, which is a time barring year for taking action u/s 148. 6. This information is forwarded to you for early dissemination to various field offices in Delhi (Soft copy also enclosed). This Court is of the opi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to be present before the ITAT on 26.02.2018 for further directions/appropriate query. The question of law is answered in favour of the Revenue and against the respondent-assessee. The appeal is allowed in the above terms. Registry is directed to communicate the order directly to the Registrar of the ITAT, Delhi Bench C , New Delhi. Order Dast ..... X X X X Extracts X X X X X X X X Extracts X X X X
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