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TMI Blog2024 (10) TMI 1285X X X X Extracts X X X X X X X X Extracts X X X X ..... ies Ltd. [ 2011 (6) TMI 4 - DELHI HIGH COURT] . The said issue was also considered by this Court in the recent decision of ATS Infrastructure [ 2024 (7) TMI 1441 - DELHI HIGH COURT] - It is not disputed that the questions of law, as projected, are covered in favour of the assessee. - HON'BLE MR. JUSTICE VIBHU BAKHRU AND HON'BLE MS. JUSTICE SWARANA KANTA SHARMA For the Appellant Through: Mr. Apoorv Kurup, GCSC for UOI with Mr. Satya Aggrawal, Advocate. For the Respondent Through: None VIBHU BAKHRU, J. (ORAL) CM APPL. 60639/2024 (condonation of delay in filing) 1. For the reasons stated in the application, the delay in filing the appeal stands condoned. 2. The application stands disposed of. CM APPL. 60640/2024 (condonation of delay ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ailed during the said period. The AO concluded that after accounting for the other transactions, in addition to the transactions relating to sales, a credit of Rs. 24,00,00,000/- remained unexplained. 10. Pursuant to the re-assessment proceedings, the AO had framed an assessment order assessing the assessee s income chargeable to tax at Rs. 65,40,00,000/- in terms of an assessment order dated 22.01.2024. The assessee preferred an appeal against the said assessment order before the CIT(A), which was allowed on the ground that no income had been brought to tax on the grounds set out in the notice issued under Section 148 of the Act. The CIT(A) reasoned that in the event no addition was made on account of the grounds as stated for re-opening t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the other additions made in the order under section 147/143(3) which were not part of the reasons recorded for reopening the assessment were sustainable in the eyes of law even after insertion of explanation 3 to section 147 of the Act by the Finance (No.2) Act, 2009? 2.2 Whether on the facts and circumstances of the case and in law, the Ld. ITAT correctly interpreted the decision reported in the case of CIT VS Jet Airways ( I) Ltd. Reported in [2011] 331 ITR 236 (Bom) and Ranbaxy Laboratories Ltd. Vs CIT reported in [2011] 336 ITR 136( Delhi) on facts of the instance case when SLP on same issue is pending before the Hon'ble Supreme Court in the case of DIT (IT2) Vs ITA-524/2024 Black Veatech Prichand Inc. in C.A. No., 9887/2018? 14. U ..... X X X X Extracts X X X X X X X X Extracts X X X X
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