TaxTMI 
TaxTMI 
2023 (7) TMI 10
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....he grounds taken by the assessee read as under: - The order of the Commissioner of lncome-tax (Appeals) in so far as it is against the assessee is contrary to law, erroneous and unsustainable on the facts of the case. Reopening of Assessment : 1. The CIT(A) erred in upholding the reopening of assessment under sec.147 of the Act. 2. The CIT(A) failed to appreciate that the reopening was based only on change of opinion by the officer since the credits in the names of M/s. Jaya Printers and Dr.Namadhu MGR are part of the regular books that was considered by the officer in the assessment u/s.143(3) and hence the reopening is untenable in law. 3. The CIT(A) further failed to appreciate that there was no reason to believe that incom....
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.... property in Thiru Vi Ka Industrial Estate. 10. The CIT(A) failed to appreciate that the assessee does not own any property in the Industrial Estate fetching any rent and is also evident from the IT and WT statements for other asst. years and hence the addition made on mere surmises is unjustified and needs to be deleted. 11. The CIT(A) erred in confirming the addition of Rs.94,12,899, received by assessee as advertisement advance under sec.68 of the Act. 12. The CIT(A) failed to appreciate that the amount was received as advance from various parties for publication of Tamil New Year Malar / souvenir by Dr. Namadhu MGR and credited in the books as advance and hence there was no basis to confirm the trade advance received by assesse....
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....ning balances. On the liability side of Balance Sheet, the details of Sundry Creditors for Rs.94.12 Lacs were not furnished. Besides, the assessee was found to have made investments during the year in various firms for which the sources were not furnished. Accordingly, the case was reopened and notice u/s 148 was issued within 4 years from the end of relevant assessment year. The assessee objected to proceedings on the ground that present proceeding tantamount to review of the concluded proceedings. However, Ld. AO referred to Explanation-1 to Sec.147 which specifically provides that production of accounts books or material evidences will not necessarily amount to disclosure within the meaning of Sec.147. Finally, the assessment proceedings....