2016 (11) TMI 1649

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....wing substantive grounds: "1.00 On the facts and circumstances of your appellant's case as well as in law, the ld. CIT(A) erred in dismissing the ground of your appellant that the order passed u/s 143(3) r.w.s. 147 of the Act by the Id. AO is bad in law, on wrong plea that your appellant has not filed the return of income with the Id. AO but with ITO, Ward 5(1), Baroda and hence reopening of assessment is prima facie justified. 1.01 Your appellant submits that it was fully explained to ld. AO with documentary evidence while objecting to reasons recorded that your appellant had filed the return of income and also offered the income on sale of property in question in the said return of income filed. Your appellant further submits th....

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....g Officer's reopening reasons recorded on 18.03.2014 as under: "Reason recorded for re-opening the assessment u/s 147 of the I.T.Act,1961 Name & Address of the Assessee              :              Amin Rajendrabhai Khundbhai 11, Anand Sagar Apartment, Anand Sagar Society, 11, Anand Sagar Apartment, Anand Sagar Society, Jetalpur Road, Jetalpur Road, Vadodara Gujarat 390007 Asst. Year                            :          &nbs....