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TMI Blog2023 (9) TMI 383X X X X Extracts X X X X X X X X Extracts X X X X ..... the AO was justified in initiating the proceedings u/s 147 of the Act. The assessee stated that the notice was issued on a wrong address. However, it is on record that the assessee has participated in the proceedings. Therefore, this ground also lacks merit. Addition u/s 69A - As stated by the assessee that assessee was having only source of income being the agriculture income. AO has not brought any other material on record suggesting that the assessee was having any other income. Assessee had clearly stated that the amount was also received from his father. AO picked up the statement partly and did not consider the fact that the father of the assessee was having a bigger piece of land. The authorities below have not made any verification ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /s 147 of the I.T. Act, 1961, without applying his own mind. 4. That the proceedings initiated u/s 147 of the I.T. Act, 1961 for AY 2009-10 are liable to be quashed because the ld. AO had initiated proceedings u/s 147 of the I.T. Act, 1961 under the wrong impression tha the appellant had invested an amount of Rs. 35,00,000/- on 28.08.2008 towards purchase of an immovable property. 5. That the proceedings initiated u/s 147 of the I.T. Act, 1961 for AY 2009-10 are liable to be quashed because the ld. AO had not specified the reason as to how & why he had formed a belief that taxable income had escaped assessment in the hands of the appellant for A.Y 2009-10. 6. That the proceedings initiated u/s 147 of the I.T. Act, 1961 for AY 2009-10 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 33/- made by the ld AO in the hands of the appellant having no income other than agricultural income, which had been confirmed by the ld CIT(A), deserves to be deleted because the ld AO had adopted a casual approach during the remand proceedings and chosen not to examine Sh. Asha Ram whose affidavit had been filed by the appellant by way additional evidence and the ld CIT(A) had not taken cognizance of such fatal lapse on the part of the ld AO. 11. That on the facts of the case under the law, the appellate order dt. 13.08.2020 passed by the ld CIT(A) Meerut deserves to be cancelled/ annulled because he had adopted a casual approach and chosen to ignore the submissions made by the appellant apropos challenge of jurisdiction". 2. Facts giv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee had purchased vide sale-deed dated 28.08.2008 an immovable property for a consideration of Rs. 35,00,000/-. In fact this property was jointly purchased. This fact was duly stated in reply filed by the assessee. 5.2. So far question of validity of initiation of proceedings for reopening of assessment is concerned, AO was having some information regarding purchase of immovable property. The assessee had not filed his return of income. Therefore, the AO was justified in initiating the proceedings u/s 147 of the Act. The assessee stated that the notice was issued on a wrong address. However, it is on record that the assessee has participated in the proceedings. Therefore, this ground also lacks merit. 5.3. Now coming to the merit of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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