9911796707
TMI Blog2024 (2) TMI 1538X X X X Extracts X X X X X X X X Extracts X X X X ..... while interfering with the order passed u/s 263 has principally taken note of the judgment rendered by the Court in Ranbaxy Laboratories Ltd. [2011 (6) TMI 4 - DELHI HIGH COURT] which had essentially held that once the AO had failed to make any additions in respect of matters on which the notice u/s 147 or 148 was founded, no other items forming part of the original order of assessment could have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Section 147 of the Income Tax Act, 1961 and whether the same would empower the Assessing Officer to assess or reassess income in respect of any issue which has escaped assessment notwithstanding the reasons recorded under sub-section (2) of Section 148 having not alluded to the same or formed the basis for reopening? X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income Tax Appellate Tribunal ["ITAT"] while interfering with the order passed under Section 263 of the Act has principally taken note of the judgment rendered by the Court in Ranbaxy Laboratories Ltd. v. CIT [2011 SCC OnLine Del 2612] which had essentially held that once the Assessing Officer ["AO"] had failed to make any additions in respect of matters on which the notice under Section 147 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2024 passed in the aforenoted ITA, we admit these appeals on the following question of law: "A. Whether Ld. ITAT has erred on the facts and circumstances of the case in not appreciating Explanation 3 of Section 147 of the Income Tax Act, 1961 and whether the same would empower the Assessing Officer to assess or reassess income in respect of any issue which has escaped assessment notwithstanding ..... X X X X Extracts X X X X X X X X Extracts X X X X
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