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TMI Blog2025 (3) TMI 1013X X X X Extracts X X X X X X X X Extracts X X X X ..... d. In this case, the exercise of jurisdiction cannot be faulted on a cumulative consideration of all such factors. The petitioner will have the full opportunity to explain the situation during the reassessment proceedings. Petitioner offered some explanations regarding the cash deposits by Mr. Ajay Pratap Singh, Mr. Rahul Mahajan and Mr. Kumar Jayendra. Apart from the quality of the explanations, at least prima facie, they appear to be in a nature of after-thoughts. We are afraid that we cannot go into such factual aspects when deciding whether the jurisdictional parameters for re-opening the assessment were fulfilled. Based on the facts of the present case and the material on record, we are satisfied that jurisdiction has been correctly ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 20th January 2017 and 9th September 2016. The reasons state that there was no clarity about collection and cash deposits by medical representatives who were prima facie and not even employed by the Petitioner on the deposit dates or who had joined just two months earlier. 6. Mr. Padvekar learned counsel for the Petitioner submitted that this was a case of assessment under Section 142 (3) of the Act. He submitted that queries were raised, and such queries were duly answered. Upon consideration of the answers, the assessment was completed. He submitted that in such circumstances, there was no scope for reopening of the assessment. Mr. Padvekar furnishes a compilation of 10 decisions but stresses on Aroni Commercials Limited Vs. Deputy Commis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d, we cannot fault the assessing authorities for having reason to believe that the income has indeed escaped assessment. The circumstance that demonetization had been ordered and there was a rush to make cash deposits also cannot be ignored. In this case, the exercise of jurisdiction cannot be faulted on a cumulative consideration of all such factors. The petitioner will have the full opportunity to explain the situation during the reassessment proceedings. 11. On 5th August 2021, the Petitioner offered some explanations regarding the cash deposits by Mr. Ajay Pratap Singh, Mr. Rahul Mahajan and Mr. Kumar Jayendra. Apart from the quality of the explanations, at least prima facie, they appear to be in a nature of after-thoughts. We are afra ..... X X X X Extracts X X X X X X X X Extracts X X X X
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