KESARWANI & CO.,ALLAHABAD vs. JT.CIT,, ALLAHABAD

In the result the appeal of the assessee is partly allowed

132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under Sections 147/148 of the Act, subject to fulfillment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved.” Therefore, in view of the decision

M/S BHOLA FOOD PRODUCTS(P) LTD.,ALLAHABAD vs. JT. CIT,(OSD),, ALLAHABAD

In the result, both the appeals filed by assessee for ay: 2005-06 and 2009-10

Bench: Shri.Vijay Pal Rao & Shri Ramit Kochar

Section 37(1) of the 1961 Act. The assessee is directed to submit all AY-2005-06 & 2009-10 relevant details/documents before the AO during the course of denovo assessment proceedings before the AO for determination of this issue. Needless to say that the AO shall provide proper and adequate opportunity of being heard to the assessee in accordance with