Case Law Details
DECIDED BY: ITAT, `D’ BENCH : MUMBAI, IN THE CASE OF: Reliance Energy Ltd. Vs. DCIT, APPEAL NO: ITA Nos. 4629, 4630, 4702 & 4703 /Mum/2009, DECIDED ON May 14, 2010
_______ORDER________
PER B RAMAKOTAIAH, AM
These cross appeals by the Revenue and the assessee are against the order of the CIT (A)-I Mumbai dated 2.6.2009 for assessment years 2001-02 and 2003-04. The issue in the appeals by the revenue is with reference to the action of the CIT (A) in holding that the initiation of reassessment proceedings u/s.147 of the Act as invalid and consequent cancellation of reassessment proceedings as bad in law. The issues in the appeals by the assessee are on merits of the additions made by the Assessing Officer in the reassessment proceedings. Consequent to the decision of the CIT (A) holding that the initiation of reassessment proceedings u/s.147 of the Act as invalid and consequent cancellation of reassessment proceedings as bad in law, he did not deal with merits of the addition made in the reassessment proceedings. The Assessee in its appeals has prayed that even on merits, the additions made by the Assessing Officer in the reassessment proceedings are unsustainable. We shall first take up for consideration the appeals by the Revenue.
2. The facts and circumstances giving raise to the appeals by the Revenue are as follows:
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