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TMI Blog2014 (6) TMI 566X X X X Extracts X X X X X X X X Extracts X X X X ..... ddition considered as bogus accommodation entries from M/s Batra Investment vide his order u/s 143(3)/147 wherein also before the CIT(A) by way of the specific grounds similar grounds were raised which it was argued have not been decided by the CIT(A) and an identical request that the issue may be restored – Decided in favour of Assessee. - I.T.A .Nos.-5867/Del/2012, I.T.A .Nos.-5868/Del/2012 - - - Dated:- 30-5-2014 - Smt Diva Singh,JJ. For the Appellant : Sh. Virender Chauhan, C.A For the Respondent : Sh. Gagan Sood, Sr. DR ORDER Per Diva Singh, JM Both these appeals are being decided by a common order for the sake of convenience. The two appeals have been filed by two different assessee s against separate ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had been raised as Revised Grounds:- 3. That under the facts and circumstances of the case and in law the Ld. AO has grossly erred in law and on facts in framing the impugned assessment u/s 143(3)/147 and that too without serving mandatory notice u/s. 148 within the statutory allowable period. Therefore, the assessment completed as such may be held ab-initio invalid. 4. That under the facts and circumstances of the case and in law the Ld. AO has grossly erred while making additions without considering the material on record; therefore, the additions made as such for Grounds of Appeals No. 1 may be liable to be deleted. 5. That under the facts and circumstances of the case and in law the Ld. AO has grossly erred while making additi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Appeals No. 1 may be liable to be deleted. 12. That under the facts and circumstances of the case and in law the Ld. AO has grossly erred while invoking Section 147 without first having statutory requirement of Section 151(2) regarding the satisfaction of the Hon ble Joint Commissioner of Income Tax, as the same is absent in the file having no comment and seal of the Hon ble Officer. As such the orders passed may be liable to be quashed and additions made as such as per Grounds of Appeals No. 1 may be liable to be deleted. 4. On a perusal of the impugned order it is seen that various legal propositions have been discussed by the CIT(A), however, the specific challenge posed to the jurisdiction of the AO vide the abovementioned grou ..... X X X X Extracts X X X X X X X X Extracts X X X X
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