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TMI Blog2024 (8) TMI 347X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal the assessee has raised following grounds : I. Reopening of Assessment: 1. On the facts and in the circumstances of the case and as per the law, the Ld CIT(A) erred in confirming the order of AO in reopening the assessment by issuing the second notice u/s 148 dated 30/03/2016 and reopening order was passed u/s 144 r.w.s 147, dated 22.12.2016 on same ground on which previous reopening notice u/s 148 dated 10/05/2013 was issued and order was passed u/s 143(3) r.w.s 147. dated. 19.03.2015. Therefore, the reopening made on the second time on the same addition is bad in law. 2. On the facts and in the circumstances of the case and as per the law. the Ld CIT(A) erred in confirming the order of A.O in reopening the assessment vide ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g in violation of the provisions of Section 250 and 251 of the Act and may be quashed. 3. Before us the Ld. Counsel for the assessee submitted that in the case of the assessee, already assessment order u/s. 143(3) r.w.s.147 was passed on 19/03/2015 based on same information about bogus purchases made from M/s. Shree Ganesh Trading Co of Rs. 4,25,880/-. The entire purchases was added made from the said party. Now again the Ld. AO had issued u/s. 148 and passed another order u/s. 144 r.w.s. 147, on 22/12/2016 making the same addition of Rs. 4,25,880/- made from Shree Ganesh Trading Company. 4. He further submitted that the addition made by the AO was accepted and no appeal was filed. Thus the assessment and the addition of Rs. 4,25,880/- h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hase from one party which has been blacklisted by Sales Tax Department, assessee's case was reopened vide notice u/s 148 dated 10/05/2013 on the ground that assessee has taken purchase bill from the following party: No Name of the entry provider Amount in the bills taken by the assessee 1 M/s. Shree Ganesh Trading Co. Rs. 4,25,880/- Total Rs. 4,25,880/- 8. The AO added the entire sum of Rs. 4,25,880/- and as against the return income of Rs. 1,83,060/-. Assessment was completed at Rs. 6,22,940/-. It has been informed that assessee accepted the said assessment and no appeal was filed. Further, the Ld. AO based on same information about the alleged bogus purchases made from Shree Ganesh Trading Company for Rs. 4,25,880/- ..... X X X X Extracts X X X X X X X X Extracts X X X X
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