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Tribunal was justified in assessing the correctness of the notice for reopening the assessment under Section 148 on the basis of the reasons which were disclosed by the Assessing Officer. Those reasons, as the Tribunal noted, could not give rise to a reason to believe that income had escaped assessment for the simple reason that in the computation of income, the assessee had adopted the circle rate which is higher than the sale consideration. Hence, the appeal will not give rise to any substantial question of law.
In the present case, the Assessing Officer has noted that the assessee had invested a certain amount of its funds in shares and that the dividend which has been received or receivable did not form part of the total income.
Sub-section (1) of Section 151 provides inter alia that where an assessment has been made under section 143(3), a notice under section 148 cannot be issued by an Assessing Officer, who is below the rank of Assistant Commissioner or Deputy Commissioner unless the Joint Commissioner
Just imagine the consequences if every part of India will be connected by Broadband and 3G/4G. 1. Education: Education is the first area that will be impacted greatly. Some school can upload videos on daily basis (say in Mumbai) and students sitting in remote villages can watch those videos. What an Idea Sirji! Yes, this will happen. Ultimately, this will be a boon for our country and all other countries that are in development stage.
