9911796707
TMI Blog2021 (4) TMI 480X X X X Extracts X X X X X X X X Extracts X X X X ..... re directed against the separate orders dated 24th January, 2019 of the CIT(A)-20, New Delhi, relating to assessment years 2007-08 and 2009-10, respectively. 2. Since identical grounds have been raised by the assessee in both these appeals, therefore, these were heard together and are being disposed of by this common order, for the sake of convenience. 3. Although a number of grounds have been r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a and various other persons was appearing. The assessee was also one such beneficiary. Accordingly, the case of the assessee was reopened as per the provisions of section 147 of the Act and notice u/s. 148 dated 14th March, 2014 was issued. One copy of the said notice was sent through speed post on 14th March, 2014 and one copy was given to the Inspector and notice server for making personal servi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enging the addition on merit, challenged the validity of reassessment proceedings. However, the Ld. CIT(A) dismissed both the issues. 6. Aggrieved with such order of the CIT(A), the assessee is in appeal before the Tribunal. 7. I have considered the rival arguments made by both the sides and perused the record. It is an admitted fact that due to non-appearance before the AO to substantiate that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ear before the AO. It is his alternate contention that given an opportunity, the assessee is in a position to substantiate his case that the assessee was not indulged in any bogus purchases, and, therefore, no addition is called for. Considering the totality of the facts of the case and in the interest of justice, I deem it proper to restore the issue to the file of the AO with a direction to gran ..... X X X X Extracts X X X X X X X X Extracts X X X X
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