Held that the reasons supplied were not the same and verbatim. The reopening of the assessment under section 147 of the Act was not sustainable. (AY 2004-05)
Jansampark Advertising and Marketing P. Ltd. v. ITO (2021) 90 ITR 32 (SN) (Delhi)(Trib.)
S. 147 : Reassessment-Accommodation entries-Reasons supplied was not the same reason recorded-Reopening of assessment was held to be not sustainable. [S. 148]