SHRI RAJEEV NATARAJ LEGAL HEIR OF LATE SHRI P NATARAJ ,BANGALORE vs. INCOME TAX OFFICER WARD-10(2), BANGALORE
In the result appeal filed by assessee stands allowed
ITA 848/BANG/2019[2008-09]Status: DisposedITAT Bangalore31 Mar 2022AY 2008-09
Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2008-09 Shri Rajeev Nataraj, L/H Of Late Shri P Nataraj, No. 63, 1St Cross, The Income Tax Udaya Nagar, Officer, Chikkalsandra, Off Ward 10(2), Uttarahalli Road, Bangalore. Vs. Bangalore – 560 061. Pan: Ahapn9475D Appellant Respondent Assessee By : Shri H. Siva Prasad Reddy, Ar : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 09-02-2022 Date Of Pronouncement : 31-03-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 11/02/2019 Passed By The Ld.Cit(A)-3, Bangalore For Assessment Year 2008-09 On Following Grounds Of Appeal: “1. The Impugned Order Passed By The Learned Commissioner Of Income-Tax [Appeals] U/S 250 Of The Act & That Of The Order Of Assessment Passed By The Learned Assessing Officer Under Section 143[3] R/W 147 Of The Act To The Extent Which Is Against The Appellant Is Opposed To Law, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Appellant'S Case. 2. The Order Of Assessment Passed By The Learned Assessing Officer Under Section 143[3] R.W.S 147 Of The Act Is Bad In Law Since The Mandatory Conditions As Envisaged
For Appellant: Shri H. Siva Prasad Reddy, AR
Section 143Section 234Section 250Section 54
54 on two residential properties, and in order to verify the alleged excess claim, issued notice under section 148 of the Act, after recording reasons for reopening that reads as under:
Page 12 of 17
10. For reopening a case u/s 147, first and foremost condition is that the AO must have ‘reason to believe’ based on some tangible material