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TMI Blog2010 (4) TMI 1217X X X X Extracts X X X X X X X X Extracts X X X X ..... of order of the Ld. CIT(A)-I, Bhopal, dated 23.10.2006, for the assessment year 2000-01. 2. We have heard both the parties and have also perused the material available on record. 3. Ground no. 1 reads as under :- On the facts and in the circumstances of the case, the Ld. CIT(A) erred in holding that A.O. had wrongly assumed the jurisdiction u/s 147 and not justified in initiating the asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thereafter, made an addition of ₹ 1,62,42,450/- after computing the production of Beer as per the methodology prescribed in such manual, which could have been against what was declared by the assessee. Aggrieved by this, the assessee carried the matter into appeal before the ld. CIT(A), on the ground that the assumption of jurisdiction u/s 147 was merely a case of reason to suspect as there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d Phoolchand Bajranglal as reported in 203 ITR 456 (S.C.). Aggrieved by this, the Revenue is in appeal before us. 6. The ld. CIT DR narrated the facts and contended that Kerala State Excise Manual was a case of information coming to the knowledge of the A.O. subsequent to making of original assessment and it was a settled judicial principle that sufficiency of reasons could not be seen nor it w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ence and reasons to suspect only. In this view of the matter, we hold that the Ld. CIT(A) has rightly quashed the assessment proceedings. Thus, this ground of the Revenue is dismissed.\ 10. In ground no.2, the Revenue has challenged the decision of Ld. CIT(A) on merits as well. However, having considered the submissions made by both the parties before us and after perusal of the order of the Ld ..... X X X X Extracts X X X X X X X X Extracts X X X X
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