TaxTMI 
TaxTMI 
2025 (9) TMI 1617
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....of appeal are as under:- 1. That the order of the Ld. CIT(A) is against law and facts of the case on the file. 2. That the Ld. CIT(A) gravely erred, in sustaining the reassessment proceedings under Section 147 and issue of notice under section 148 as the AO wrongly assumed jurisdiction to frame the reassessment. 3. That the Ld. CIT(A) erred in sustaining the reassessment proceedings in view of the judgment of Hon'ble Punjab & Haryana High Court in the case of Jasjit Singh Vs. Union of Indian and others in CWP- 21509-2023 (P&H) decided on 29.07.2024 as the proceedings were initiated without conducting the faceless assessment as envisaged under Section 144B of the Income Tax Act, 1961. 4. That the Ld. C....
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....sment on the basis of 'Iqrarnama' found from the premises of Sh. Chuni Lai Gaba on 18.03.2014 and it was claimed by the assessee that he does not know the said Sh. Chuni Lai Guba. The basic reason for issuance of notice u/s 148 were as under: i). 'Iqrarnama' was found from the premises of Shri Chuni Lai Gaba during the course of survey action on 18.02.2014 wherein, it has been stated that the assessee has given an advance of Rs. 53,00,000/- to Sh. Vijay Kumar s/o Shri Gian Chand on an interest of 2% per month. On the basis of such' Iqrarnama', it was alleged that the assessee has advanced a loan of Rs. 53,00,000/- for nine months i.e. July, 2012 to 31.03.2013 from the unexplained/ undeclared sources and hence, the amount of....
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....s of the assessee and, further, the assessee also enquired that the Sh. Vijay Kumar S/o Sh. Gian Chand had expired long back and even the father's name mentioned in the 'Iqrarnama' of the assessee is also not correct. No cross examination' of the person have been allowed to the assessee by the Assessing Officer. Lastly, it was a third-party document and there is no link or connection of the said document with the assessee at all. v). It was further argued that the Assessing Officer/CIT(A) have failed to link the assessee with Sh. Chuni Lai Gaba 'Group', from where, the said document was impounded. Even the blank cheques duly singed by Sh. Vijay Kumar had no name of the assessee and further to that, no corrob....
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....he order of the Assessing Officer, order of the CIT(A), arguments of the Ld. Counsel and the Ld. Sr. DR, who relied upon the recovery of the 'Iqrarnama' from the premises of Sh. Chuni Lai during survey, where the name of assessee have been mentioned. The assessee right from the beginning has denied it. The signatures on the 'Iqrarnama' are forged and there is no identification nor his 'Aadhar Card Number' or 'PAN on it. He furnished a report of the handwriting expert. We have gone through the report of the handwriting expert and find that the said report is detailed one and the Assessing Officer has not been able to rebut such documentary evidence. Report of the handwriting expert is that the signatures on the &#....