2026 (3) TMI 166

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....nt Years 2011-12 to 2014-15. Since the issues raised in all the appeals are identical and common, the same is being heard together for the purpose of convenience and brevity. We are taking grounds of appeal in ITA No.820/Srt/2025 for the purpose of adjudication. ITA No.820/Srt/2025 for A.Y 2011-12 2. The assessee has raised the following grounds of appeals: 1. On the facts and in the circumstances of the case as well as the law on the subject, the learned Commissioner of the Income Tax (Appeals has erred in confirming the action of the Assessing Officer in reopening the assessment u/s 147 of the act and issuing notice u/s 146 of the Income Tax Act 2. On the facts and in the circumstances of the case as well as The....

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....ll as before us during the hearing, the assessee has consistently maintained the stand that the bank account was misused by one Shri Mayur Barwaliya, Proprietor of Shree Impex, and that all the monies came from Shree Impex and were withdrawn by Shri Mayur Barwaliya. To buttress his argument, the assessee submitted the entire details of the bank account, which are reproduced as under: Bank account at page no. 3 year-wise. A.Y ADDITION GROSS BANK CREDIT CHQ NET BANK CREDIT           2011-12 2,34,46,670 2,34,46,670 5,50,000 2,28,96,670           2012-13 57,13,000 57,13,000 0 57,13,000       ....