2015 (9) TMI 56

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....h Shah PER SHRI A.K.GARODIA ACCOUNTANT 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] ....

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....he case, the Ld.CIT(A) ought to have upheld the 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 ....

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....see to disclose material facts truly and correctly. He has also 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....

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....ok because the same are available in assessment records also. 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....