In the result this ground of appeal is also rejected

Bench: Shri Pawan Singh, Hon'Ble & Dr. Shri Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A No.1487/Ahd/2012 "नधा"रण वष"/Assessment Year: 2005-06 The Income Tax Officer, Vs. Shri Rajkumar Goyal, Ward-7(3), Surat. Prop. Of Balaji Corporation, 201, Keshri Nandan Apartment, Bhothia Sheri, Rughnathpura, Surat – 395003. [Pan: Adtpj 2924 Q] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओर से /Assessee By Shri P.M.Jagasheth - Ca राज"वक"ओर से /Revenue By Shri Ritesh Mishra – Cit-Dr सुनवाई की तारीख/ Date Of Hearing: 18.03.2021 उ"घोषणा क" तार"ख/Pronouncement On: 17.05.2021 आदेश /O R D E R Per Pawan Singh, Judicial Memeber: 1. This Appeal By The Revenue Is Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-V, Surat Hereinafter Referred As “Ld. Cit(A)” Dated 29.03.2012 For The Assessment Year (Ay) 2005-06. The Revenue Has Raised Following Grounds Of Appeal: “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit (A) Has Erred In Deleting The Addition On Account Of Unverifiable Purchase Amounting To Rs. 7,91,01,863/-. 2. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit (A) Has Erred In Deleting The Addition On Account Of In Difference In Closing Balance Of Rs.8,05,11,522/-. 3. It Is Therefore Prayed That The Order Of The Ld. Cit (A) Be Set Aside & The Assessing Officer ‘S Order Be Restored.”

270 ITR 469 Guj) and decisions of Tribunal in ITO Vs Smt Gurinder Kaur ( 2006) ITD 189/105 TTJ 198 and ACIT Vs Raj Kumar Jain [IT(SS) A No. 28/Del/2012] dated 08.07.2015. 9. In rejoinder submissions the Ld. CIT-DR for the revenue submits that the assessee never raised objections against the reopening during the reassessment before the assessing officer