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Showing contexts for: settlor beneficiary same in Hasmukh I Gandhi, Mumbai vs Dcit Cen Cir 1, Mumbai on 15 November, 2017Matching Fragments
The grounds are common except for the change in amounts involved. For the sake of reference, the grounds of appeal from ITA No. 2795/Mum/2011 are being referred as under:
1. The learned CIT (Appeal) has erred in law and on sustaining the order of the A. O. reopening the assessment u/s. 147 of the Income Tax Act.
2. The learned CIT (Appeal) has erred in law and on the facts or sustaining the addition of Rs.37,67,807/- without appreciating the fact that the A. O. had no authentic material before him relating to the trust, trustee, settlor, beneficiaries, whether the trust is specific or discretionary and dates of deposit in the bank account.