2014 (11) TMI 1203

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....pta,   This appeal by the assessee for the Asstt.Year 2001-2002 is directed against the order of the CIT(A), Baroda. 2. The grounds of the appeal of the assessee are as under: "1. The ld.CIT(A) erred in fact and in law in confirming the action of the AO in invoking the provisions of section 147 for reopening the assessment and consequently making the assessment u/s.147 r.w.s. 143(3) of ....

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....of Rs,.4,00,000/- on the ground that it is not justifiable. 6. The ld.CIT(A) erred in fact and in law in confirming the action of the AO in making disallowance of Director's remuneration paid to Smt. Induben P. Mehta, Rs. 72,000/- p.a. and Rs. 75,000/- paid to Smt. Trapti N. Mehta." 3. The learned counsel for the assessee submitted that the action of the AO in invoking the provision of sectio....

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....(A) in support of the  case of the Revenue. He relied on the decision of the Crown Consultants P. Ltd. v. Commissioner of Income-tax, 44 taxmann.com 397 (Bom). 5. We have considered rival submissions. We find that the assessee has requested in its written submissions before the CIT(A) for copy of reasons recorded by the AO while reopening assessment under section 147 of the Act, and the sam....