2005 (2) TMI 472

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....o, these are being disposed of by this common order for the sake of convenience. 2. All these assessees had filed their respective appeals for asst. yr. 1979-80 and the same had been accepted. Thereafter, search and seizure operation was carried out in the group of cases of one Shri Prem Raj Khiv Raj Singhvi in the year 1981 and on the information received from DDI, Bombay, vide his letter dt. ....

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....ned AO has erred in: 1. continuing the proceedings under s. 147/148 of the Act, which was erroneously initiated on the basis of unspecific information inasmuch as concerned alleged lender did not name the assessee-firm with whom he entered in impugned financial transaction, nor any such material in directing so was supplied to the appellant. 2. the appeal may very kindly be allowed on this l....

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....(2004) 82 TTJ (Asr)(SB) 729 : (2005) 92 ITD 85 (Asr)(SB), wherein it was held that initiation of reassessment proceedings would be valid if alleged creditor confesses that so-called loan transaction with assessee was not genuine and he acted as a name lender, but initiation of reassessment proceedings would be invalid where alleged creditor confesses or states that he was a name lender to some par....