2025 (5) TMI 190

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....ecured loan without considering the evidence available in the assessment records of the assessee. 3. That the Ld. CIT(Appeals) erred in confirming the addition of Rs. 11,89,000/- towards cash deposited in bank account without considering the evidence available in the assessment records of the assessee. 4. That on the fact and in the circumstances of the case and in law, the Ld. CIT(Appeals) erred in confirming that the reassessment was validly carried out by the Ld. Income Tax Officer, Ward 40(5) despite the followings: i) Four years had elapsed from the end of relevant assessment year and having disclosed fully and truly all material facts necessary for assessment, no reassessment proceedings is permissible under the law; ii) N....

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.... submissions made by the assessee the Assessing Officer has proceeded to make the addition of Rs. 97,740/- with the finding that assessee failed to explain the source of deposits. With the above facts on record he submitted that he processed the ground no.4 which is raised by the assessee on jurisdictional issue and submitted that the present assessment was reopened beyond four years and the Assessing Officer has not brought on record any failure on the part of the assessee to disclose fully and truly all material facts. 3. Considering the fact that the assessment was reopened beyond four years and also assessment was completed u/s 143(3) of the Act since the proviso to section 147 is applicable failure on the part of the Assessing Officer....