Ramesh Chand Soni Huf, Jaipur vs Ito, Beawar on 8 December, 2017
Shri Ramesh Lal Jain (HUF) Vs. ITO 19(3)(1), Mumbai 7
ITA No. 7057/Mum/2017
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1 - 2 of 2 (0.20 seconds)Ramesh Salecha Huf, Mumbai vs Ito 14(2)(3), Mumbai on 25 October, 2017
Subsequent recording of reasoning after issuance of Notice
is not permissible, any additions or amendments in
reasons to believe is also not permissible Ld. A.O. has
merely relied on DIGT(I) Mumbai and Sales Tax
Shri Ramesh Lal Jain (HUF) Vs. ITO 19(3)(1), Mumbai 2
ITA No. 7057/Mum/2017
Department informations, has not made any inquiries in
that respect, relied on borrowed informations and opinions
of other authorities, are also not allowed for reopening of
the completed assessment proceedings. Therefore, Notice
u/s. 147/148 is liable to be quashed and all collateral
proceedings are also liable to be annulled and / or set
aside. This ground is not decided by Ld. CIT(A), Mumbai
which goes to the root of the matter. A.O. has not given the
copy of reasons records at the time of issuing of Notice
u/s/^7/148 of the Act. to the Appellant.
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