SHRI SANDEEP MEHTA,NEEMUCH vs. INCOME TAX OFFICER, NEEMUCH
In the result, we answer the question in the affirmative i
ITA 71/IND/2018[2009-10]Status: DisposedITAT Indore17 Aug 2021AY 2009-10
Bench: Shri Rajpal Yadav & Shri Manish Boradिनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष"/ Assessment Year : 2009-10 वष" Shri Sandeep Mehta, The Income Tax Officer, S/O. Shri Jay Singh Mehta, Vs Neemuch Vijay Talkies Chouraha, Neemuch (Mp) Pan : Adbpm 8174 B "" यथ"/ (Respondent) अपीलाथ"/ (Appellant) Assessee By : Shri S.N. Agrawal & Shri Pankaj Mogra, Ars Revenue By : Shri Harshit Bari, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 02/08/2021 घोषणा क" तार"ख /Date Of Pronouncement: 17 /08/2021 आदेश/O R D E R Per Rajpal Yadav: The Assessee Is In Appeal Before The Tribunal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Ujjain (Mp) Dated 28.11.2017 Passed For Assessment Year 2009-10. 2. In The First Ground Of Appeal, The Assessee Has Challenged Reopening Of Assessment By Issuance Of Notice Under Section 148 Of The Income-Tax Act, 1961. 3. The Learned Counsel For The Assessee, While Impugning The Orders Of The Revenue Authorities, Contended That The Assessment Was Reopened For The Reason That The Assessee Has Made Cash Deposits Amounting To Rs.11,00,000/-, Without Disclosing The Source Of Deposits & This
For Appellant: Shri S.N. Agrawal &For Respondent: Shri Harshit Bari, Sr. DR
Section 147Section 148
26. If the contention of the assessee that even after introduction of Explanation 3 to Section 147 of the Act, the situation has not undergone any material change is accepted, the question that immediately would come to one s mind is, what then was the purpose of introducing such an explanation. An argument may arise that if before and after
