TaxTMI 
TaxTMI 
2019 (7) TMI 292
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....the Ld. Assessing Officer ('Ld. AO') pursuant to which reassessment proceedings were initiated, were unsustainable; 2. That on the facts and circumstances of the case and in law, the order passed by the Ld. AO as upheld by the Hon'ble CIT(A) is barred by limitation, inasmuch as, there was no failure on the part of the Appellant to fully and truly disclose material facts, in terms of first proviso to Section 147 of the Act; 3. That having regard to the facts and circumstances of the case and in law, the impugned order is presumptuous, prejudiced and based on incorrect factual position; 4. That on the facts and circumstances of the case and in law, the Ld. AO had grossly erred by not disposing off the ob....
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....s of appeal are without prejudice and notwithstanding each other. The Appellant craves leave to add, amend, vary, omit or substitute any of the aforesaid grounds of appeal at any time before or at the time of hearing of the appeal. 2. The brief facts of the case are that an information was received from the Investigation Wing, Kolkata that during the course of search operation in the case of Sh. Praveen Aggarwal and his group companies, it was established that the said Mr. Praveen Aggarwal, had floated paper companies for providing accommodation entries. The said Mr. Agarwal in his statement u/s. 134(4) admitted that one of his group of companies, M/s Tuticorin Trexim Pvt. Ltd. which had received commission from various companie....
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....ts (India) Ltd. vs. ITO and others (2003) 259 ITR 19 (SC). It was further submitted that Ld. CIT(A) has not taken into consideration the objection filed by the assessee against the 'reasons to believe' stated by the AO. In view of above, he requested that issues in dispute may be set aside to the file of the AO with the directions to first decide the aforesaid objection and then decide the issue in dispute afresh, after giving adequate opportunity of being heard to the assessee. 4. On the contrary, Ld. DR relied upon the orders of the authorities below. 5. We have heard both the parties and perused the records, especially the assessment order passed u/s. 143(3)/147 of the Act and the impugned order. We find that assessee has filed the....
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.... challenging the validity of notices issued under sections 148 and 143(2) of the Income-tax Act, 1961. The High Court took the view that the appellant could have taken all the objections in its reply to the notices and that, at that stage the writ petition was premature. Accordingly, the writ petition was dismissed on January 31, 2002. Aggrieved by that order, the appellant is in appeal before us. Mr. M. L. Verma, learned senior counsel appearing for the appellant, submits that the impugned notices relate to seven assessment years ; that during; the pendency of these appeals, in respect of two assessment years, viz., 1995-96 and 1996-97, assessment has been completed against which appeals have been filed. Notices ....