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TMI Blog2018 (2) TMI 1945X X X X Extracts X X X X X X X X Extracts X X X X ..... ved by the order of the Income Tax Appellate Tribunal (ITAT), filed the instant appeal under Section 260A of the Income Tax Act, 1961 ('the Act'); the year in question is AY 2004-05. The Assessing Officer (AO) had made assessment under Section 143(1) in the first instance on the returns of the assessee under Section 141 of the Act; later, acting upon the information received, assessment was re-ope ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enue. The Revenue had premised the re-opening of assessment on the basis of a statement made by one Mr. S.K. Gupta. The AO in the re-assessment order refused to give effect to the retraction of that statement, brushing aside the later statement, on the ground that it was made years later. At the same time, this Court for another Assessment Year (AY 2002-03) held that whilst it was open to the AO t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 184/- on the basis that expenses claimed for various activities such as web advertising, web designing, commission of franchise advertisement charges and software development, as claimed, could not be sustained, as the entries with respect to the service providers were bogus. The AO premised his findings largely upon statement of one Mr. S.K. Gupta on 13.12.2006, who stated that he had provided en ..... X X X X Extracts X X X X X X X X Extracts X X X X
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