2017 (4) TMI 1349

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....by the assessee against the order passed by the ld. CIT(A)-I, Kanpur dated 22.6.2016 pertaining to assessment year 2010-11. 2. The appeal filed by the assessee is late by 3 days. The assessee has filed petition for condonation of delay. After hearing both the parties, I condone the delay. 3. The only issue involved in this appeal is whether the proceedings initiated under section 147/148 of ....

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..... 6. I have heard both the parties and carefully considered the same along with the orders of the authorities below. I noted that in this case proceedings under section 147 of the Act has been initiated by the Assessing Officer by recording the following reasons:- "Reasons for issuing notice under section 148 of I.T. Act, 1961. The assessee has sold a property for Rs. 21462000/- (value....