2022 (5) TMI 364

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....e, is directed against the order of the learned Commissioner of Income-tax (Appeals)-16, New Delhi, dated 27.05.2019, pertaining to the assessment year 2011-12. The assessee has raised following grounds of appeal: "1. Ld. AO have to make the addition of such income for which notice u/s 148 was issued then only he can make the addition of any other income, because in wording of section 147....

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....efore the learned CIT(Appeals), who after considering the submissions, dismissed the appeal. Now the assessee is in appeal before this Tribunal. 5. No one appeared on behalf of the assessee. It is seen from that from various occasions no one is representing the assessee. Notice sent by speed post has been served upon the assessee as acknowledgement is available on record. Therefore, the appeal ....

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.... of the information. 8. I have heard learned DR, perused the material on record and gone through the orders of the authorities below. Admittedly, in the present case the assessment was reopened on the basis of cash deposited in the bank account and no addition has been made by the Assessing Officer regarding deposit of this amount. It is seen that the assessee has not raised this issue before t....

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....e assessment u/s 147 of the Act. After reopening of assessment, the Assessing Officer can in his wisdom proceed to make assessment regarding other issues as well. There is no prohibition under law that the Assessing Officer is required to confine assessment on the issue for which the assessment was reopened by him. Hence, ground nos. 1 and 2 of the assessee's appeal are devoid of any merit and sta....