ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2, GUWAHATI vs. FORTUNE VANIJYA PRIVATE LIMITED, GUWAHATI
In the result both the appeal of the Revenue and the cross objections of the assessee stands partly allowed
ITA 21/GTY/2021[2011-12]Status: DisposedITAT Guwahati10 Dec 2021AY 2011-12
Bench: Shri P.M. Jagtap, Hon’Ble V.P (Kz) & Shri A. T. Varkey, Jm]
Section 132Section 132(4)Section 142(1)Section 153ASection 153CSection 68
68 of the Act, which according to him, lends credence to his argument that the jurisdictional fact was indeed absent and hence, the action of AO is bad in law for want of jurisdiction.
14. So, first let us examine whether this legal contention of Shri Dudhwewala that existence of the undisclosed asset valued Rs. 50 lakh or more discovered