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TMI Blog2019 (10) TMI 1004X X X X Extracts X X X X X X X X Extracts X X X X ..... of the firm vide order dated 25.02.2015 accepting the explanation given by the firm. As further pointed out that in this case, the reopening is based upon a search carried out at the premises of K. Star group on 17.08.2016. It was submitted that, under the circumstances, the Assessing Officer could not have assumed jurisdiction under section 147 of the Act and a notice under section 153C could ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the reasons recorded for reopening of assessment for the Assessment Year 2012-13 to point out that the Assessing Officer has recorded that the partnership firm M/s. Akshar Associates had purchased property having document value of ₹ 2,70,00,000/- at Vadodara. That, a search came to be carried out on K. Star group and papers related to purchase of such property was found wherein, the payme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot reflected therein and such document is dated 31.03.2016, whereas, the Assessing Officer seeks to reopen the assessment for the Assessment Year 2012-13. It was submitted that, therefore, the document at Annexure 'G' is a dumb document and has no connection or live nexus with the formation of belief and that, on the basis of such document, no reasonable person could have come to the concl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reopening is based upon a search carried out at the premises of K. Star group on 17.08.2016. It was submitted that, under the circumstances, the Assessing Officer could not have assumed jurisdiction under section 147 of the Act and a notice under section 153C could have been issued, if permissible. 4. Having regard to the submissions advanced by the learned counsel for the petitioner, issue Noti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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