2012 (8) TMI 1225

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....ndhu ORDER Per N.R.S. Ganesan (JM) All the appeals of the two independent assessees are directed against two common orders passed by the Commissioner of Income-tax(A)-III, Kochi dated 11-01-2012. 2. Shri Mathew Joseph, the ld.representative for the assessees submitted that the assessing officer completed the assessments u/s 144 of the Act without giving sufficient opportunity to the as....

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....rtunity before the Commissioner of Incometax( A). 4. We have considered the submissions on either side and also perused the material available on record. Admittedly, the assessments were completed u/s 144 of the Act. The assessing officer claims in the assessment orders that by letter dated 15-11-2010 the assessees were requested to explain the source of credits in the bank account by 22-11-201....

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....ssees had a fair opportunity before the Commissioner of Income-tax(A). In these factual circumstances, in our opinion, the assessing officer has to reconsider the issue after giving reasonable opportunity of hearing to the assessees to produce the material in order to explain the source of investment in the bank deposits. Giving one more opportunity to the assessee may not prejudice the interest o....