Acit 32 1, Mumbai vs Vidhi Enterprises, Mumbai on 28 November, 2024
6.1 We have heard rival submission of the parties on the issue in
dispute and perused the relevant material on record. It is
undisputed that despite sale proceedings the assessee did not file
return of income. Under Explanation -2 below the provisions of
section 147 of the Act, non-filing
filing of return of income also invite
reopening of assessment proceedings. Further, the Ld. CIT(A) has
also dismissed the arguments of the assessee that Assessing Officer
cannot make addition on the other issues which did not form part
of reasons recorded citing the decision of the Co
Co-ordinate
ordinate Bench in
the case of Gujarat State Financial Corporation v. CIT (supra).
Accordingly, we do not find any infirmity in the order of the Ld.
CIT(A) on the issue in dispute. The ground No. 1 of the appeal of the
assessee is accordingly dismissed.