TMI Blog2019 (8) TMI 110X X X X Extracts X X X X X X X X Extracts X X X X ..... new tangible material in the hands of the AO at the time of initiating the reassessment proceedings u/s 147 of the Act and at the time of issuing the notice u/s 148. Having regard to the finding of fact recorded by the Appellate Tribunal, we are not inclined to disturb the order. None of the questions as proposed by the Revenue would be termed as substantial question of law involved in this Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ( A) Whether on the facts and circumstances of the case and law Hon'ble ITAT has erred in setting aside reopening of assessment made by the AO under section 147 of the Act ? ( B) Whether on the facts and circumstances of the case and law Hon'ble ITAT has erred in setting aside addtiion of ₹ 1,92,000/- made by the AO under section 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of section 40A(3) of the Act and thereafter in para 4 alleged that from the scrutiny of the record and submissions made by the AO, it is notices that the assessee had paid ₹ 9,60,000/- in cash to Shri Suresh C. Desai which required to be disallowed under section 40 A(3) of the Act. Thereafter, in last para, the AO jumped to form a reason to believe that the income has escaped assessment ther ..... X X X X Extracts X X X X X X X X Extracts X X X X
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