9911796707
TMI Blog2002 (2) TMI 332X X X X Extracts X X X X X X X X Extracts X X X X ..... 83, 1983-84, 1984-85 and 1986-87 respectively and are directed against the common order of CIT(A), Jodhpur, dt. 28th Feb., 1992. 3. We have heard the arguments of both the sides and also perused the records. 4. The Revenue has raised the sole common ground disputing the cancellation of assessment (reassessment) in asst. yrs. 1982-83 and 1983-84, and has disputed the deletion of addition of pro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e four assessment years. 6. As against the above the learned authorised representative of assessee has relied on the orders of learned CIT(A). He has contended that the additions in professional receipts have been made without any basis whatever. He has contended that there was no evidence/material on record for making such estimate by AO and so the learned CIT(A) rightly deleted the addition. H ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as also relevant material on record. From the perusal of record it is revealed that the AO has made the addition in professional receipts observing that the assessee has not maintained any accounts of his professional receipts and of household expenses and so he made addition in professional receipts on estimated basis holding that the assessee met his household expenses (over and above this is s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot adjudicated upon validity of initiation of proceedings under s. 147/148. In the situation, the question of validity of notice under s. 148 having not been decided/adjudicated upon by the learned Dy. CIT(A), is of no consequence before us though raised in the ground before us by Revenue. In that view of the matter, we find no infirmity in the impugned order of learned CIT(A). We, therefore, decl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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