Dismissing the petition the Court held that ;even assuming that there was no specific direction in the order passed by the CIT(A), the Assessing Officer was entitled to exercise his powers under S. 148 of the Act, as there was no opportunity to verify the transactions claimed to have been made in those years. The notice was valid. ( AY. 2010-11 to 2012-13)
Alfa Investments. v. ITO (2018) 400 ITR 445/ 161 DTR 155 / 300 CTR 85 (Mad) (HC)Editorial: Affirmed by division Bench , Alfa Investments. v. ITO (2018) ( 2018) 304 CTR 425 ( Mad) (HC) Editorial: Affirmed by division Bench , Alfa Investments. v. ITO (2018) ( 2018) 304 CTR 425 ( Mad) (HC)
S. 147: Reassessment —Cash credits –No specific direction- Finding of the CIT(A) in assessment year , 2012-13 stating that the amount assessable in the years 2009-10 and 2010 -2011- Reassessment was held to be valid [ S. 68, 148 ]