2014 (5) TMI 990

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....D.R. ORDER Per Shri Kul Bharat, Judicial Member : These three appeals by the assessee are directed against the common order of the Ld.Commissioner of Income Tax(Appeals)-I, Baroda ('CIT(A)' for short) dated 24/01/2011 pertaining to Assessment Years (AYs) 1994-95, 1995-96 & 1996-97. Since common issues are involved, these appeals were heard together and are being disposed of by way of this....

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....s prayed that, since, each and every entry in the bank account stands duly and fully explained, the addition of Rs.11,10,095/- made by the learned assessing officer be knocked off in toto. It may further be noted that neither the Hon.CIT(A) nor the learned assessing officer has raised any further query in response to our detailed submissions for each and every bank transactions. Your appellant com....

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.... r.w.s. 147 of the Act was framed, thereby the AO made addition of Rs.11,10,095/- and this addition was made on protective basis. Against this order, the assessee filed an appeal before the ld.CIT(A), who after considering the submissions, dismissed the appeals pertaining to AYs 1994-95, 1995-96 and 1996-97. Now, the assessee is in further appeal before us. 3. The ld.counsel for the assessee su....

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....g assessment proceedings u/s.147 of the Act, the additions have been made in respect of the same bank account and the same amount which has been added in the block assessment on substantive basis. However, additions made in the reopening assessment proceedings are on the protective basis. 5.1. The Revenue has not controverted the contention of ld.counsel for the assessee that the same addition ....