2007 (2) TMI 167

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....er shall dispose of I. T. A. Nos. 571 and 574 of 2006. 2. The facts are being referred from I. T. A. No. 571 of 2006. The assessee-appellant has approached this court by filing the aforementioned appeal under section 260A of the Income-tax Act, 1961, claiming that the following substantial questions of law would emerge out of the order dated April 19, 2006, passed by the Income-tax Appellate Tr....

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....n of the Assessing Officer in specific wherein the Assessing Officer has clearly defied the judgment of the hon'ble Supreme Court of India in the case of GKN Driveshafts (India) Ltd. v. ITO [2003] 259 ITR 19 wherein it has been clearly held that the Assessing Officer cannot proceed with the assessment proceeding without first disposing of the objections raised by the assessee against the reasons r....

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....her, on the facts and circumstances of the case, the Income-tax Appellate Tribunal was justified in confirming the action of the authorities below by upholding the addition made on account of impugned gift of Rs.1 lakh? F. Whether, on the facts and circumstances of the case, the Income-tax Appellate Tribunal was justified in confirming the action of the authorities below by allowing only partia....

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....reasons were recorded by the competent authority for initiation of proceedings under section 148 of the Act. The sufficiency thereof cannot be gone into by this court. It could not be successfully argued that the reasons did not have any nexus with the material available with the Assessing Officer. The authorities below have disbelieved receipt of gifts claimed by the assessee-appellant from Jaswi....