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TMI Blog2025 (1) TMI 576X X X X Extracts X X X X X X X X Extracts X X X X ..... in the case of M/s. Cricket South Africa (Association) [ 2023 (10) TMI 1318 - ITAT DELHI] are not common with the reasons as recorded in the case of the Assessee, but it is undisputed that the reasons as recorded contain material errors, as are noted above. Clearly, the question is not whether the errors are identical but whether the AO had applied its mind to the question of reopening the assessment in the case of the Assessee. Since, it is not disputed that the brief reasons as recorded by the AO for reopening of the assessment in the Assessee s case contain material errors, the decision of the ITAT to fault the reopening of the assessment, does not warrant any interference by this court. No substantial question of law arises. - HON' ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the present case, the reasons set out for reopening of the assessment are similarly worded as the reasons set out for reopening of the assessment in the case of M/s. Cricket South Africa (Association) in respect of AY 2014-15. The reasons for reopening in respect of both the cases have been set out by the learned ITAT in the impugned order. 5. The reasons for reopening of the assessment in the case of the Assessee are reproduced below: - Reasons of reopening of the assessment in the case of M/s. Cricket Australia, for Assessment Year 2013-14 u/s.147 of the Act. Name of the assessee M/s Cricket Australia Address of the assessee 60, Jolimont Street Jolimont Victoria, Australia, AU 3002 Foreign PAN of the assessee AFECC5341D Assessment Year 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ded in the said reasons. 7. Mr Bhatia, the learned counsel appearing for the Revenue submits that paragraph no. 4 of the reasons as set out by the Assessing Officer (AO) for reopening of the assessment in case of the M/s Cricket South Africa (Association) were identically worded as the reasons for reopening of the assessment in the case of the Assessee in the present case. Even the name of the assessee was referred as M/s. Cricket Australia instead of M/s. Cricket South Africa. Further the AY in that case was AY 2014-15, which was erroneously mentioned as AY 2013-14. He submits that however the contents of the paragraph no. 4 of the reasons as recorded in case of the Assessee are correct and free from any errors. 8. The focus of his submiss ..... X X X X Extracts X X X X X X X X Extracts X X X X
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