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 - 7 of 7 (0.18 seconds)Section 147 in The Income Tax Act, 1961 [Entire Act]
Section 148 in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
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.
Commissioner Of Income-Tax-I vs Simit P on 16 January, 2013
In the backdrop of his aforesaid
deliberations the A.O relied on the judgment of the Hon‟ble High Court
of Gujarat in the case of CIT vs. Simit P. Sheth (2013) 356 ITR 451
(Guj) and quantified the profit element that the assessee would had
made by carrying out purchases from undisclosed sources @ 12.5% of
the aggregate value of such purchases of Rs. 3,86,87,972/-, resulting
to a consequential addition of Rs. 48,35,997/- in the hands of the
assessee.
Commissioner Of Income Tax` vs Gulshan Kumar Luthra Huf on 28 February, 2019
Our aforesaid view is fortified by
the judgment of the Hon‟ble High Court of Bombay in the case of CIT
Vs. Premkumar Arjundas Luthra (HUF)(2016) 240 Taxman 133 (Bom).
We thus in terms of our aforesaid observations restore the appeal to
the file of the CIT(A) with a direction to dispose off the same on merits.
Needless to say, the CIT(A) in the course of the set aside proceedings
shall afford an opportunity of being heard to the assessee.
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