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        <h1>Assessee deemed to accept reassessment by not appealing, can contest only Section 68 cash credit addition</h1> <h3>PR. COMMISSIONER OF INCOME TAX -FARIDABAD Versus GREEN GEM ESTATES PVT. LTD.</h3> HC held that the assessee had not challenged the reassessment proceedings before CIT(A) and, as evident from the memo of appeal, the only grievance raised ... Validity of reopening of assessment - Unexplained cash credit u/s 68 - HELD THAT:- Perusal of memo of appeal - CIT(A) has erred in law in deleting the addition made by AO on account of unexplained cash credit u/s 68 of the Act received from M/s Queen Commercial Pvt. Ltd. It is thus manifest that the appellant never questioned the validity of the findings returned by the Commissioner of Income Tax (Appeals) [“CIT(A)”] insofar as reassessment is concerned. The Tribunal noted that 'the aspect of re-opening of assessment and its validity was never questioned before it.' The Court examined the memo of appeal, which contained the following grounds of appeal: '1. The order of Ld. CIT(A) is not correct in law and on facts. 2. On the facts and circumstances of the case, the Ld. CIT(A) has erred in law in deleting the addition of Rs. 29,85,00,000/- made by AO on account of unexplained cash credit u/s 68 of the Act received from M/s Queen Commercial Pvt. Ltd. 3. The appellant craves leave to add, amend any/all the ground of appeal before or during the course of hearing of the appeal.' It was held that the appellant 'never questioned the validity of the findings returned by the Commissioner of Income Tax (Appeals) insofar as reassessment is concerned.' Appeal found to have 'no merit' and was dismissed.

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