TaxTMI 
TaxTMI 
2015 (9) TMI 56
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....NT MEMBER: This is an appeal filed by the Revenue, and the Cross Objection is filed by the Assessee. These are directed against the order of ld. CIT(A)-I Surat dated 24.12.2012 for Asst. Year 2005-06. Grounds raised by the Revenue in its appeal and grounds raised by the Assessee in the Cross Objection are as under:- Grounds raised by the Revenue [1] On the facts and circumstance of the case a....
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.... order of the Assessing Officer. Grounds raised by the assessee in Cross Objection: 1. The Ld.CIT(A) has not dealt with the merits of the ground of addition of disallowance of proportionate interest of Rs. 7,96,000/-. 2. The Ld.CIT(A) has not dealt with the merits of the ground of addition u/s.40(a)(ia) of the Act of Rs. 6,42,444/-. 3. It is therefore prayed that if the validity of re-assessm....
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....lso noted that in the present case, the original assessment was completed by the AO u/s.143(3) of the Act and the re-opening is after four years from the end of the relevant assessment year. As per the assessment order, we also find that it is noted by the AO in the assessment order that the original assessment was completed u/s.143(3) of the Act on 26/12/2007 and he has also noted that notice u/s....
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..... As per the reasons recorded by the AO for re-opening of the assessment, it is seen that it is noted by the AO in the reasons that the reasons are on the basis of perusal of the assessment records and there is no allegation that there was nay failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment. In the present case, it is established that....