2025 (3) TMI 1983

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.... Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Year 2012-13. 2. The Assessee has taken the following grounds of appeal:- 1. Whether, on facts and in circumstances of the case and in law, Ld.CIT(A) has erred in law in confirming disallowance of business expenses of Rs. 13,97,010/- as u/s.37 of the Act. 2. Whether, on facts and in law, Ld. Assessing officer has erred in issuing notice u/s.148 of the Act. Further, appellant craves leave to add, amend, alter or withdraw all or any ground of appeal. 3. The brief facts of the case are that the assessee is engaged in the trading of cotton yarn. The assessee filed return of income declaring total income at Rs. 14,85,170/- The asse....

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.... Tribunal, the assessee has not only contested the addition made by the Assessing Officer on merits but has also raised the legal issue on the validity of the reopening of the assessment. 6. I have heard the rival contention of both the parties. A perusal of the assessment order reveals that the Assessing Officer has mentioned therein the reasons recorded for reopening to the assessment. On perusal of the aforesaid para No. 2 of the order reveals that no new information had come to the knowledge and possession of the Assessing Officer to form the belief that the income of the assessee had escaped assessment. The opening lines mentioned by the Assessing Officer are that " verification of the case records, it is seen that the assessee.........