2025 (9) TMI 300

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....ed matter in as much as earlier order dated 27.09.2024 passed by the Tribunal has been recalled vide M.A.No.66/PUN/2024 dated 07.02.2025. 3. Assessee has raised following grounds of appeal : "1. The learned CIT(A) erred both in law and in facts in initiating reassessment proceedings based on the information relating to some other person and resorted to reassess income on the basis of incorrect information. 2. The learned CIT(A) erred both in law and in facts in making an addition of Rs. 26,32,178/- without appreciating the facts of the case. 3. The appellant prays that addition of Rs. 26,32,178/- made to the income of the appellant be deleted. 4. The appellant craves leave to add, alter, modify or subs....

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....fore us. So far as the legal issue raised by the assessee challenging the validity of notice u/s. 148 of the Act and the assessment proceedings, we fail to find any merit because the information was received by the ld. AO for the transaction between the assessee and Mahalaxmi Marketing. However, after recording of reasons, assessee failed to raise any objection challenging the reasons recorded and it left no option with the AO except to proceed for the re-assessment proceedings. Assessee could have challenged the validity of notice u/s. 148 of the Act by requesting for the reasons recorded but in absence thereof the assessee has accepted the notice u/s. 148 of the Act and then re-assessment proceedings have been carried out validly. Therefo....