2025 (2) TMI 1401

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....er passed by Assessing Officer (AO for short) u/s 143(3) r.w.s. 147 of the Act dated 03.12.2019. Grounds of appeal raise by the assessee are as under: "1. Ld. Addl/JCIT[A]-5, Mumbai has erred in law and on fact to upheld AO's order for reopening of assessment u/s 147 and issue of notice u/s 148 of the Act. 2. Ld.Addl/JCIT[A]-5, Mumbai has erred in law and on fact to uphold AO's addition of Rs. 3,38,820/- being entire credit side of appellant's bank account with Bank of India, Chikhli Branch, Valsad ignoring the fact that the appellant is a senior citizen, having only agriculture income. 2. Facts in brief are that assessee is a senior citizen and deposited cash of Rs. 2,79,842/- in her bank account during the year under ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ng re-assessment proceedings which are as under: Sr. No. Section Date of issue Din 01 148 29/3/2019 ITBA/AST/S/148/2018-19/1015507934(1) 02 148 29/3/2019 ITBA/AST/S/148/2018-19/1015507934(2) 03 142[1] 26/8/2019 ITBA/AST/F/142(1)/2019-20/1017571706(1) 04 LETTER 17/11/2019 ITBA/AST/F/17/2019-20/1020583116(1) 05 SCN 27/11/2019 ITBA/AST/F/17/2019-20/1021142880(1) 06 ORDER 03/12/2019 20121078107 4.1 The Ld. AR of the assessee relied on the decision of Hon'ble Supreme Court in the case of Asstt. CIT vs. Hotel Blue Moon (2010) 321 ITR 362/188 Taxman 113 (SC) and the decisions of Hon'ble jurisdictional High Court in the cases of (i) CIT vs. Panorama Builders Pvt.....