6 CIT in v. Mohmed Juned Dadani

The DCIT, Circle-4(1)(1), Ahmedabad vs. Mrunal Santramdas Verma, Ahmedabad

…before or at the time of hearing.” 4. At the outset, the counsel for the assessee challenged the re-opening of assessment in instant set of facts and placed reliance on the decision of the jurisdictional Gujarat High Court in the case of Mohmed Juned Dadani 355 ITR 172 (Gujarat), wherein the High Court held that when the ground on which reopening of assessment was based, no addition was made by Assessing Officer, he could not make additions on some other grounds which did not form part of reasons recorded by him. The counsel for the assessee submitted that no additions were made in respect of those issues which…