LAXMAN D DAWARE,MUMBAI vs. ITO 19 (2)(1), MUMBAI
In the result, appeals of the assessee are partly allowed as indicated above
ITA 3464/MUM/2018[2011-12]Status: DisposedITAT Mumbai30 Sept 2019AY 2011-12
Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble
For Appellant: Shri Prakash PanditFor Respondent: Shri Chaitanya Anjaria
Section 133(6)Section 143(3)Section 145Section 147
…formation by belief by AO is essentially within his subjective satisfaction - at the stage of issue of notice, only question is whether there was relevant material on which reasonable person could have formed requisite belief. 3) N.K. Industries Ltd. vs. ITO 362 ITR 542 (Guj.) where the Hon'ble HC held if a particular issue is brought to the notice of the AO by audit party and AO of his /her application of mind finds this ground as valid, reopening of assessment cannot be quashed merely because such ground was brought to the notice of AO by the audit party. 4) The Hon'ble Supreme Court in the case of ACIT vs. Ra…