2019 (11) TMI 1757

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....T This is an appeal by the Assessee against the order dt. 16/01/2019 of Ld. CIT(A)-1, Udaipur. 2. Following grounds have been raised in this appeal: 1. In the facts and circumstances of the case the Ld. Assessing Officer and CIT(A) both has erred in not accepting the source of money or cash received from joint account holders viz. Smt. Vimala Jain, Pranita Jain and Nikhil Jain, whic....

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....rocessed under section 143(1) of the Income Tax Act, 1961 (hereinafter referred to as 'Act') on 15/05/2011. Later on, the Assessing Officer issued the notice under section 148 of the Act to reopen the assessment. The Assessing Officer observed that cash amounting to Rs. 16,00,000/- was deposited in Bank Account No. 784107791 in the Inidan Bank, Udaypur Branch in the name of five persons namely Gar....

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....000/- from genuine sources. 5. Now the assessee is in appeal and challenged the issuance of notice under section 148 vide ground No. 1 & 2. 6. The Ld. DR submitted that these grounds were not adjudicated by the Ld. CIT(A) as the same were not raised before him, so these are the new grounds therefore the same may not be considered. 7. Ld. Counsel for the assessee submitted that the grounds....