2022 (7) TMI 395

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....sessee against order dated 29.11.2019 of learned Commissioner of Income Tax (Appeals)-42, New Delhi, for the assessment year 2011-12. 2. The grounds raised by the assessee are as under: 1. Ld/CIT(A) did not consider; notice issued u/s 148 was time barred which is bad in law. 2. Ld/CIT(A) did not consider; the assessment order, demand notice u/s 143(3) r.w.s. 147 was unsigned a....

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....'the Act'). Whereas, the Assessing Officer received information that the assessee had deposited amount of Rs.18 lakhs in an account held in Bank of India. Thus, based on such information, the Assessing Officer reopened the assessment under section 147 of the Act. In course of assessment proceeding, the Assessing Officer called upon the assessee to explain the source of deposit made in the bank acc....

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.... explain the source of such deposits, the Assessing Officer treated them as unexplained money under section 69A of the Act and added back to the income of the assessee. Addition so made, was also upheld by learned Commissioner (Appeals). 4. Before us, learned counsel for the assessee submitted, the assessment was reopened to assess the deposits of Rs.18 lakhs in the account held with Bank of In....

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....terials on record. It is evident, based on AIR information indicating that the assessee had made investment of Rs.18 lakhs in fixed deposits with Bank of India, the Assessing Officer reopened the assessment under section 147 of the Act. In course of assessment proceeding, the assessee furnished documentary evidence and submitted that the fixed deposit made is of Rs.3 lakhs and not 18 lakhs. On cro....