RAJ HANS TOWERS PVT. LTD. Vs. ITO

JUDGEMENT

(1.) THIS is an appeal filed by the assessee directed against the order of ld. CIT(A) dated 14.2.2013 for the assessment year 2004 -05.

(2.) FACTS in brief : The assessee is a private Ltd. Company and it filed its return of income on 23.8.2004 declaring income of Rs. 11,000/ -. The return of Income was processed u/s. 143(1). Later notice u/s. 148 of the Act dated 31.3.2011 was issued to the assessee. The assessee filed a reply dated 11.4.2001, wherein it has stated that, the return of income filed u/s. 139 of the Act on 23.8.2004, be treated as a return filed in response to notice u/s. 148 of the Act. The assessment was completed on 15.12.2011 u/s. 147 r.w. section 143(3) determining total income of Rs. 2,14,38,400/ -. Aggrieved the assessee carried the matter in appeal, challenging both the reopening of assessment as well as the merits of the addition. The first appellate authority dismissed the appeal of the assessee. Aggrieved the assessee filed this appeal on the following grounds: - -

(3.) THE ld. Counsel for the assessee relied on the following case laws in support of his argument: - -