2021 (12) TMI 1514

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....YA, ACCOUNTANT MEMBER: This appeal by the assessee is preferred against the order of the Commissioner of Income Tax [Appeals] - 09, New Delhi dated 26.11.2019 pertaining to A.Y 2011-12. 2. The assessee has raised as many as five grounds of appeal but before us the ld. AR insisted upon Ground No. 1.3 which reads as under: "1.3 That on the facts and in the circumstances of the case and in law, I....

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....isputed fact is that the assessment order dated 26 12.2018, which is framed under section 147 r.w.s 143(3) of the Act. It is also not in dispute that the reasons for reopening assessment relates to information/ evidences unearthed during the course of operation conducted on Shri Anand Kumar Jain and Shri Naresh Kumar Jain group of cases on 17.12.2015. 5. On these facts, it was incumbent upon the ....