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TMI Blog2022 (2) TMI 1360X X X X Extracts X X X X X X X X Extracts X X X X ..... at the deposited cash was in the nature of undisclosed income or not? - as argued deposit of cash during the demonetization period had been disclosed in the return itself - HELD THAT:- In the present case, the reassessment notice had been issued within four years of filing of the assessment and there had been no scrutiny assessment of the petitioner. The only requirement for reopening of assessmen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not been raised by the petitioner in its objection petition and consequently, the same has not been dealt with by the Revenue while deciding the petitioner s objections. Accordingly, in the event, the petitioner wishes to raise the issue of lack of sanction by the appropriate authority, the petitioner shall be at liberty to do so during the reassessment proceedings. X X X X Extracts X X X X X X X X Extracts X X X X ..... t of cash during the demonetization period, which had been disclosed in the return itself. He states that a bare perusal of the recorded reasons would reveal that there was no fresh material in the possession of respondent No.1 to form the belief that the deposited cash was in the nature of undisclosed income of the petitioner. Learned counsel for the petitioner states that reopening provisions c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of the subjective satisfaction of the Assessing Officer or judge the sufficiency of the reasons recorded and/or determined whether such opinion is based on tangible, concrete and new information that is capable of supporting such a conclusion. [See: Raymond Woolen Mills Ltd. vs. ITO (1999) 236 ITR 34 (SC)]. The petitioner herein had admittedly deposited Rs.11,40,000/- in cash in his bank accoun ..... X X X X Extracts X X X X X X X X Extracts X X X X
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