TaxTMI 
TaxTMI 
2019 (11) TMI 1757
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....inst 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 Vimala Jain, Pranita Jain and Nikhil Jain, which they have withdrawn from their bank account and c....
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....nafter 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 Garima, Pranit, Vimla, Nikhil, Prakash i.e.; the assessee. He also ....
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....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 challenging the initiation for reopening the assessment is purely legal....