2022 (4) TMI 444

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.... grounds of appeal: "1. On the facts and circumstances of the case, the CIT(A) erred in holding that the initiation of assessment u/s. 147 vide notice of u/s. 148 of the IT Act was bad-in-law, thereby failing to appreciate that the proceedings were duly initiated after recordings the reasons as per procedure of law. 2. On the facts and circumstances of the case, the CIT(A) erred in failing to appreciate that the reason are arbitrary and wrong whereas the case was reopened because there was huge difference in turnover between the information received and as per return of income of the assessee. 3. On the facts and circumstances of the case, the CIT(A) erred in failing to appreciate that once none of the grounds, recorded in the reaso....

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.... date of limitation period to reopen the assessment. He has submitted that the assessee was not given any opportunity to file objections against the reopening of the assessment. Since the assessee have been denied the opportunity to contest the reopening, therefore, the reopening of the assessment was bad in law. The ld. Counsel for the assessee has further submitted that, even otherwise, the reasons recorded did not constitute reliable information to form the belief by the Assessing Officer that income of the assessee for the year under consideration has escaped assessment. He, therefore, has relied upon the impugned order of the CIT(A). 4. We have heard the rival contentions of both the ld. representatives of the parties and gone through....